106168 Federal Register / Vol. 89, No. 248 / Friday, December 27, 2024 / Rules and Regulations 

1For purposes of this release, we use the term 

‘‘filer’’ to mean ‘‘electronic filer,’’ as defined in Rule 

11 of Regulation S–T: ‘‘A person or an entity that 

submits filings electronically pursuant to Rules 100 

or 101 of Regulation S–T.’’ 

2For a discussion of the current EDGAR access 

and account management processes, please refer to 

EDGAR Filer Access and Account Management, 

Release No. 33–11232 (September 13, 2023) [88 FR 

65524 (September 22, 2023)] (‘‘Proposing Release’’). 

3For a discussion of the 2021 Request for 

Comment, please refer to the Proposing Release. 

4Comment letters related to the 2021 Request for 

Comment are available at https://www.sec.gov/ 

comments/s7-12-21/s71221.htm. 

5Memoranda describing these meetings with SEC 

officials are available at https://www.sec.gov/ 

comments/s7-15-23/s71523.htm. 

SECURITIES AND EXCHANGE 

COMMISSION 

17 CFR Parts 232, 239, 249, 269, and 

274 

[Release Nos. 33–11313; 34–101209; 39– 

2557; IC–35343; File No. S7–15–23] 

RIN 3235–AM58 

EDGAR Filer Access and Account 

Management 

AGENCY: Securities and Exchange 

Commission. 

ACTION: Final rule. 

SUMMARY: The Securities and Exchange 

Commission (‘‘Commission’’) is 

adopting rule and form amendments 

concerning access to and management 

of accounts on the Commission’s 

Electronic Data Gathering, Analysis, and 

Retrieval system (‘‘EDGAR’’) that are 

related to certain technical changes to 

EDGAR (collectively referred to as 

‘‘EDGAR Next’’). EDGAR Next will 

improve the security of EDGAR, 

enhance filers’ ability to manage their 

EDGAR accounts, and modernize 

connections to EDGAR. The 

amendments require electronic filers 

(‘‘filers’’) to authorize and maintain 

designated individuals as account 

administrators and to take certain 

actions, through their account 

administrators, to manage their accounts 

on EDGAR. Further, pursuant to these 

amendments, filers may only authorize 

individuals as account administrators or 

in the other roles described herein if 

those individuals first obtain individual 

account credentials in the manner 

specified in the EDGAR Filer Manual. 

As part of the EDGAR Next changes, 

optional Application Programming 

Interfaces (‘‘APIs’’) will be offered to 

filers for machine-to-machine 

communication with EDGAR. Moreover, 

we are amending Volume I of the 

EDGAR Filer Manual to accord with 

these changes. Filers will have 12 

months from the issuance of this release 

to transition to EDGAR Next. 

DATES: 

Effective date: The effective date for 

this rule is March 24, 2025. The 

incorporation by reference of certain 

material listed in this rule is approved 

by the Director of the Federal Register 

as of March 24, 2025. 

Compliance date: The compliance 

date for amended Form ID is March 24, 

2025. The compliance date for all other 

rule and form amendments (other than 

the EDGAR Filer Manual changes) is 

September 15, 2025. See SUPPLEMENTARY

INFORMATION for more information on 

compliance and the EDGAR Filer 

Manual changes. 

FOR FURTHER INFORMATION CONTACT: 

Rosemary Filou, Deputy Director and 

Chief Counsel; Daniel K. Chang, Senior 

Special Counsel; E. Laurita Finch, 

Senior Special Counsel; Jane Patterson, 

Senior Special Counsel; Margaret 

Marrero, Senior Counsel; Lidian Pereira, 

Senior Special Counsel; EDGAR 

Business Office at 202–551–3900, 

Securities and Exchange Commission, 

100 F Street NE, Washington, DC 20549. 

SUPPLEMENTARY INFORMATION: The 

Commission is adopting amendments to 

17 CFR 232.10 (‘‘Rule 10’’) and 17 CFR 

232.11 (‘‘Rule 11’’) under 17 CFR part 

232 (‘‘Regulation S–T’’); and 

amendments to Form ID (referenced in 

17 CFR 239.63, 249.446, 269.7, and 

274.402). The Commission is also 

adopting an updated Filer Manual, 

Volume I: ‘‘EDGAR Filing,’’ Version 42 

(issued September 27, 2024) and 

amendments to 17 CFR 232.301 (‘‘Rule 

301’’). The updated Filer Manual is 

incorporated by reference into the Code 

of Federal Regulations. 

Table of Contents 

I. Introduction 

II. Discussion 

A. Individual Account Credentials 

B. Individual Roles: Account 

Administrator, User, Technical 

Administrator 

1. Account Administrators 

2. Users 

3. Technical Administrators 

C. Delegated Entities 

1. Delegating Authority To File 

2. Separation of Authority of Filer and 

Delegated Entity 

3. Delegated Entities 

4. Delegated Users 

5. User Group Functionality at Delegated 

Entities 

6. Technical Administrators at Delegated 

Entities 

D. Hours of Operation of the Dashboard 

E. Optional Application Programming 

Interfaces 

1. APIs That Commission Staff Will 

Provide 

2. API Tokens 

F. Final Amendments to Rules and Forms 

1. Rule 10 of Regulation S–T 

2. Rule 11 of Regulation S–T 

3. Form ID 

G. EDGAR Filer Manual Changes 

H. Transition Process 

1. Enrollment Process 

2. Compliance 

III. Other Matters 

IV. Economic Analysis 

A. Baseline 

B. Consideration of Benefits and Costs as 

Well as the Effects on Efficiency, 

Competition, and Capital Formation 

1. Benefits 

2. Costs 

3. Effects on Efficiency, Competition, and 

Capital Formation 

C. Reasonable Alternatives 

1. Add and Allow Bulk Confirmation for 

Related CIKs 

2. Extend the ABSCOMP Process to 

Affiliated Entities 

3. Retire the CCC for Filing Submissions 

4. Requirements for Individual and Small 

Filers 

5. Implementing Performance-Based 

Standards 

V. Paperwork Reduction Act 

A. Summary of Comment Letters on PRA 

Estimates 

B. Form ID 

C. The Dashboard 

VI. Final Regulatory Flexibility Analysis 

A. Need for and Objectives of the Rule and 

Form Amendments 

B. Significant Issues Raised by Public 

Comments 

C. Small Entities Subject to the Rule and 

Form Amendments 

D. Projected Reporting, Recordkeeping, and 

Other Compliance Requirements 

E. Agency Action to Minimize Effects on 

Small Entities 

Statutory Authority 

Appendix A—Form ID 

I. Introduction 

The Commission is seeking to 

enhance the security of EDGAR, 

improve the ability of filers 1 to securely 

manage and maintain access to their 

EDGAR accounts, facilitate the 

responsible management of filer 

credentials, and simplify procedures for 

accessing EDGAR.2

In furtherance of these goals, on 

September 30, 2021, the Commission 

issued a Request for Comment on 

Potential Technical Changes to EDGAR 

Filer Access and Filer Account 

Management Processes (‘‘2021 Request 

for Comment’’).3 The Commission 

received comments in response to the 

2021 Request for Comment,4 and 

Commission staff subsequently engaged 

in a dialogue with commenters and 

other interested parties,5 considered 

feedback from these parties, and 

gathered additional information about 

filers’ interactions with EDGAR. Staff 

discussed a variety of topics with 

commenters including the addition of 

optional APIs for submission and for 

verifying certain information on 


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Federal Register / Vol. 89, No. 248 / Friday, December 27, 2024 / Rules and Regulations 106169 

6The public comments we received are available 

at https://www.sec.gov/comments/s7-15-23/ 

s71523.htm. A few commenters asserted that the 

comment period was not sufficient and asked the 

Commission to extend it. See Comment Letter of 

XBRL US (October 27, 2023) and Toppan Merrill 

Comment Letter (November 20, 2023) (‘‘Toppan 

Merrill Comment Letter’’). The comment period for 

the Proposing Release was open for 60 days, and we 

do not believe an extension of the comment period 

is necessary. Moreover, we have considered all 

comment letters received, including those 

submitted after the comment period closed. 

7 In addition to the changes discussed below, 

Rule 10 is being amended to implement certain 

clarifying and conforming changes. See section 

II.F.1. 

8We are amending Rule 11 of Regulation S–T to 

define ‘‘individual account credentials’’ as 

credentials issued to individuals for purposes of 

EDGAR access, as specified in the EDGAR Filer 

Manual. See the discussion of amendments to Rule 

11 in section II.F.2. The EDGAR Filer Manual is 

being amended to specify that individual account 

credentials must be obtained through Login.gov, a 

sign-in service of the U.S. Government that employs 

multifactor authentication. 

9We are amending Rule 11 of Regulation S–T to 

define the ‘‘dashboard’’ as an interactive function 

on EDGAR where electronic filers manage their 

EDGAR accounts and individuals that electronic 

filers authorize may take relevant actions for 

electronic filers’ accounts. See the discussion of 

amendments to Rule 11 in section II.F.2. In 

connection with this rulemaking, the dashboard 

will be integrated into the EDGAR Filer 

Management website, https://

www.filermanagement.edgarfiling.sec.gov. 

10We are amending Rule 11 of Regulation S–T to 

define an ‘‘account administrator’’ as an individual 

that an electronic filer authorizes to manage the 

electronic filer’s EDGAR account on EDGAR, and to 

make filings on EDGAR on the electronic filer’s 

behalf. See the discussion of amendments to Rule 

11 in section II.F.2. Applicants (individuals and 

companies) for EDGAR access must authorize 

account administrators on Form ID. See amended 

Form ID. 

11We are amending Rule 11 of Regulation S–T to 

define ‘‘authorized individual.’’ This definition 

mirrors the definition of ‘‘authorized individual’’ in 

the EDGAR Filer Manual, Volume I. See the 

discussion of amendments to Rule 11 in section 

II.F.2 and EDGAR Filer Manual, Volume I. 

12For example, if a filer wishes to authorize an 

individual employed by its filing agent to act as the 

filer’s account administrator, the filer must upload 

with the Form ID a power of attorney signed by an 

authorized individual of the filer, with that 

signature notarized, authorizing the employee of the 

filing agent to be the filer’s account administrator. 

See amended Form ID, Part 3. The EDGAR Filer 

Manual, Volume I sets forth the requirements for 

notarization of the signature of an authorized 

individual. Among other things, pursuant to 

Volume I of the EDGAR Filer Manual, notarization 

may be obtained through a remote online notary 

recognized by the law of any State or territory in 

the U.S. or the District of Columbia. 

13We are amending Rule 11 of Regulation S–T to 

define an ‘‘Application Programming Interface’’ or 

‘‘API’’ as a software interface that allows computers 

or applications to communicate with each other. 

See the discussion of amendments to Rule 11 in 

section II.F.2. 

14We are amending Rule 11 of Regulation S–T to 

define a ‘‘technical administrator’’ as an individual 

that the filer authorizes on the dashboard to manage 

the technical aspects of the filer’s use of EDGAR 

APIs on its behalf. See the discussion of 

amendments to Rule 11 in section II.F.2. Technical 

administrators need not be software developers or 

technical experts to carry out the requirements to 

manage the filer’s use of APIs and filer API tokens, 

as discussed more fully below. 

EDGAR; filers’ annual confirmation of 

the accuracy of their account 

information; whether accession 

numbers should be traceable to the 

individuals making the submissions; 

bulk submissions and user group 

functionality; delegation of authority to 

file; a potential transition process to 

implement the contemplated changes; 

and other technical matters. 

After consideration of the information 

provided by commenters in response to 

the 2021 Request for Comment, the 

Commission issued a Proposing Release 

on September 13, 2023, that included 

proposed amendments to Rule 10 of 

Regulation S–T concerning filer access 

and account management and related 

matters; Form ID, the application for 

EDGAR access; and Rule 11 of 

Regulation S–T, containing the 

definitions of terms in Regulation S–T. 

The Commission proposed changes to 

Rule 10 and Form ID to require each 

EDGAR filer to authorize and maintain 

individual account administrators to 

manage the filer’s EDGAR account on a 

dashboard on EDGAR and to authorize 

account administrators and other 

individuals only if those individuals 

obtained individual account credentials. 

The Commission further proposed that 

each filer, through its account 

administrators, be required to confirm 

annually that the filer authorized all 

individuals and delegated entities 

reflected on the dashboard to act on its 

behalf, and that all information about 

the filer on the dashboard was accurate. 

The Commission also proposed 

requirements to maintain accurate and 

current information on EDGAR 

concerning the filer’s account and 

securely maintain information relevant 

to the ability to access the filer’s EDGAR 

account. In addition to the proposed 

rule and form amendments, the 

Commission described in the Proposing 

Release the possible addition of optional 

APIs to allow machine-to-machine 

submissions on and retrieval of certain 

information from EDGAR and indicated 

that, to connect to the optional APIs, 

filers, through their account 

administrators, would be required to 

authorize at least two technical 

administrators and present certain 

security tokens to EDGAR as specified 

in the EDGAR Filer Manual. 

The Commission considered comment 

letters received in response to the 

Proposing Release that included both 

comments on the proposed rule and 

form changes as well as technical 

feedback on functionality discussed in 

the Proposing Release.6 We considered 

both the comments on the rule and form 

amendments as well as feedback on 

EDGAR Next technical functionality and 

discuss both aspects together in this 

release. While we discuss aspects of 

EDGAR Next technical functionality in 

this release together with the final rule 

and form amendments, we anticipate 

that this technical functionality will 

evolve over time in response to, for 

example, changes in filer needs, security 

requirements, and technological 

developments, among other 

circumstances. As is the case today and 

has been historically, updates to the 

EDGAR system typically will be 

communicated through the EDGAR Filer 

Management website and reflected in 

amendments to the EDGAR Filer 

Manual from time to time. 

The Commission is adopting the 

proposed amendments to Rules 10 and 

11 of Regulation S–T and Form ID 

substantially as proposed. We believe 

that the rule and form amendments 

adopted in this release and the related 

technical changes further the goals of 

enhancing the security of EDGAR access 

and improving EDGAR account 

management and are responsive to the 

comments received in response to the 

Proposing Release and the 2021 Request 

for Comment. 

The obligations for filers are generally 

being codified in Rule 10 of Regulation 

S–T, new paragraph (d).7 Under 

paragraph (d)(1) of Rule 10 as adopted, 

only those individuals who obtain 

individual account credentials 8 can be 

authorized to act on the filer’s behalf on 

the dashboard on EDGAR.9 Paragraph 

(d)(2) of Rule 10 as adopted requires 

each filer to authorize and maintain 

individuals as its account 

administrators 10 to manage the filer’s 

EDGAR account on the filer’s behalf, in 

accord with the EDGAR account access 

and account management requirements 

set forth in this release and in the 

EDGAR Filer Manual as it is being 

amended. Pursuant to the amendments 

to Form ID and the EDGAR Filer 

Manual, the filer can authorize someone 

who is not an employee of the filer or 

its affiliates to be the filer’s account 

administrator if an authorized 

individual for the filer 11 provides a 

relevant notarized power of attorney.12

Paragraph (d)(3) of Rule 10 as adopted 

requires any filer that decides to 

connect to an optional API 13 to 

authorize, through its account 

administrators, at least two technical 

administrators 14 to manage the API 

unless the filer arranges to use the filer 

API tokens and API connections of its 


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106170 Federal Register / Vol. 89, No. 248 / Friday, December 27, 2024 / Rules and Regulations 

15See paragraph (d)(3) of Rule 10 as adopted 

addressing the technical administrator requirements 

and the provision therein allowing filers to use their 

delegated entities’ API connections and filer API 

tokens so long as those delegated entities comply 

with the requirement to maintain two technical 

administrators. 

16We are amending Rule 11 of Regulation S–T to 

define a ‘‘user’’ as an individual that the filer 

authorizes on the dashboard to make submissions 

on EDGAR on the filer’s behalf. See the discussion 

of amendments to Rule 11 in section II.F.2. 

17We are amending Rule 11 of Regulation S–T to 

define a ‘‘delegated entity’’ as an electronic filer 

that another electronic filer authorizes, on the 

dashboard, to file on EDGAR on its behalf. See the 

discussion of amendments to Rule 11 in section 

II.F.2. 

18As an example of the changes being made to 

make the form more user friendly, additional 

instruction will be added to guide applicants 

through completion and submission of the form, 

and the user interface will be improved. 

19As an example of the changes being made to 

improve the utility of the form for Commission 

staff, a checkbox will be added to each address field 

for identification of non-U.S. locations, which will 

improve data analytics. 

20Please refer to amended Rule 11 of Regulation 

S–T, set forth in this release, for definitions of the 

terms used in the release. The amendments to Rule 

11 also update or delete reference to outdated 

terminology and clarify the definition of the EDGAR 

Filer Manual. 

21 In total, the enrollment period will extend nine 

months, from March 24, 2025 to December 19, 2025. 

If filers enroll on the dashboard during this period, 

they will not be required to apply for access on 

amended Form ID. Please see section II.H for 

additional information about enrollment. 

22See EDGAR Next-Improving Filer Access and 

Account Management, U.S. Securities and 

Exchange Commission, available at https://

www.sec.gov/edgar/filer-information/edgar-next. 

23A blackline of the changes to Volume I of the 

EDGAR Filer Manual is available at www.sec.gov/ 

rules-regulations. 

delegated entities.15 Further, the 

EDGAR Filer Manual is being amended 

to require that filers present certain 

security tokens to connect to the APIs. 

As adopted, paragraph (d)(4) of Rule 10 

will require each filer, through its 

authorized account administrators, to 

confirm annually that all account 

administrators, users,16 delegated 

entities,17 and technical administrators 

reflected on the dashboard for the filer’s 

EDGAR account are authorized by the 

filer and that all information regarding 

the filer on the dashboard is accurate. 

Paragraph (d)(5) of Rule 10 as adopted 

will require each filer, through its 

authorized account administrators, to 

maintain accurate and current 

information about the filer on EDGAR, 

and paragraph (d)(6) of Rule 10 as 

adopted will require each filer, through 

its authorized account administrators, to 

securely maintain information relevant 

to the ability to access the filer’s EDGAR 

account. 

We are amending Form ID to 

implement the changes to Rule 10, 

including but not limited to the 

requirement to provide information 

about the applicant’s account 

administrators, to make the form more 

user friendly,18 and to improve the 

utility of the form for Commission 

staff.19 Moreover, we are amending Rule 

11 of Regulation S–T to define new 

terms related to the rule and form 

amendments.20 We are further 

amending the EDGAR Filer Manual to 

accord with the EDGAR Next changes. 

The EDGAR Next transition process 

will begin with the issuance of this 

adopting release. For the initial six 

months, from September 30, 2024 to 

March 21, 2025, filers may prepare for 

the changes by testing in and modifying 

their internal software systems to accord 

with an EDGAR Next Adopting Beta 

environment reflecting the adopted rule 

and form amendments and related 

technical changes, including but not 

limited to testing the optional APIs that 

will be provided, as well as gathering 

information necessary to enroll on 

EDGAR. On Monday, March 24, 2025, a 

new EDGAR Filer Management website 

that includes the dashboard will go live, 

and related changes in the EDGAR Filer 

Manual, Volume I will be effective. At 

that time, compliance with amended 

Form ID will be required, all applicants 

for EDGAR access must apply on 

amended Form ID through the 

dashboard, and the prior version of the 

form will be ineffective. If Commission 

staff grant the amended Form ID 

application, the filer will be in 

compliance with the EDGAR Next 

changes, and thus will not be required 

to subsequently enroll on the 

dashboard. In addition, beginning 

Monday, March 24, 2025, existing filers 

may begin to enroll on the dashboard, 

and once enrolled may connect to the 

optional APIs while still being able to 

use the legacy filing process. 

Compliance with the remaining EDGAR 

Next changes will be required on 

Monday, September 15, 2025, when all 

EDGAR websites will require, among 

other things, Login.gov individual 

account credentials and dashboard 

authorization to make submissions on 

EDGAR. Filers who have not enrolled by 

September 15, 2025 will not be able to 

make submissions or take other actions 

in EDGAR other than enroll. Enrollment 

will be permitted for an additional three 

months, until December 19, 2025.21 On 

December 22, 2025, filers who have not 

enrolled in EDGAR Next or been granted 

access through amended Form ID will 

be required to submit the amended 

Form ID through the dashboard to apply 

for access to their existing EDGAR 

accounts. Section II.H below provides 

additional information regarding the 

transition to EDGAR Next. 

Additional details regarding EDGAR 

Next technical changes, including 

dashboard functionality and APIs, as 

well as the transition process are 

available on the EDGAR Next page on 

SEC.gov.22

II. Discussion 

We are adopting, substantially as 

proposed, amendments to Rule 10 of 

Regulation S–T concerning EDGAR filer 

access and account management and 

related matters; Form ID, the application 

for EDGAR access; and Rule 11 of 

Regulation S–T, containing the 

definitions of terms in Regulation S–T. 

We are further amending the EDGAR 

Filer Manual in accord with the rule 

and form amendments.23 These 

amendments will, among other things, 

benefit filers by improving the security 

of their EDGAR accounts and making it 

easier for filers to manage and maintain 

access to their EDGAR accounts. 

The amendments to Rule 10 and Form 

ID set forth requirements for each 

EDGAR filer to authorize and maintain 

individual account administrators to 

manage the filer’s EDGAR account on a 

dashboard on EDGAR and to authorize 

to act on the filer’s behalf only those 

individuals who obtain individual 

account credentials. The EDGAR Filer 

Manual is being amended to specify 

Login.gov as the individual account 

credential provider. Each filer, through 

its account administrators, will be 

required to confirm annually that all 

account administrators, users, technical 

administrators, and delegated entities 

reflected on the filer’s dashboard are 

authorized by the filer to act on its 

behalf and that all information regarding 

the filer on the dashboard is accurate; 

maintain accurate and current 

information on EDGAR concerning the 

filer’s account; and securely maintain 

information relevant to the ability to 

access the filer’s EDGAR account. 

In addition to the rule and form 

amendments, this release describes the 

EDGAR Next functionality that will be 

offered to filers, including but not 

limited to optional APIs that will 

improve the efficiency and accuracy of 

filers’ interactions with EDGAR by 

providing a machine-to-machine 

method of making submissions, 

retrieving information, and performing 

account management tasks. EDGAR will 

make available 15 optional APIs in total, 

which include the three APIs discussed 

in the Proposing Release and 12 

additional APIs, many of which were 

requested by commenters. Among other 

things, these APIs will replicate much of 


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24https://www.login.gov/. 

25See Login.gov, ‘‘About us,’’ at https://

www.login.gov/about-us/. 

26As of the date of this release, Login.gov 

multifactor authentication options include: (1) a 

security key; (2) Federal government employee or 

military PIV or CAC cards; (3) authentication 

application; (4) biometric (face or fingerprint) 

verification; (5) text message/SMS or telephone call; 

and (6) backup codes. With respect to option (3), 

current Login.gov authentication applications 

include: Android and iOS options (Google 

Authenticator, Authy, LastPass, 1Password), 

Windows and Mac apps (1Password and OTP 

Manager), and Chrome extensions (Authenticator). 

See generally Login.gov, Authentication Options at 

https://www.login.gov/help/get-started/ 

authentication-options/. See also generally 

Login.gov, ‘‘Privacy and security: Our security 

practices,’’ at https://login.gov/policy/our-securitypractices/ for information on Login.gov’s security 

practices. 

27 If an individual changes the email address that 

she uses in connection with EDGAR (for example, 

because of a change of domain name), the 

individual should first change her email address on 

the dashboard and then change it on Login.gov. This 

will prevent interruptions in access to EDGAR. If 

an individual permanently loses access to her email 

before taking the steps above, the individual should 

create another account on Login.gov with a new 

email address, and the filer’s account administrator 

should add her to the filer’s account on the 

dashboard using the new email address. 

28 If the individual loses or forgets her Login.gov 

password, the individual can reset the password 

through Login.gov, simplifying and automating the 

process of password retrieval. 

29See Exec. Order No. 14028 (2021), 60 FR 26633, 

26636 (May 17, 2021). 

30See Digital Identity Guidelines: Authentication 

and Lifecycle Management, National Institute of 

Standards and Technology, NIST SP 800–63, 

available at https://csrc.nist.gov/pubs/sp/800/63/b/ 

upd2/final, at section 4 of NIST SP 800–63B (‘‘Any 

PII or other personal information—whether selfasserted or validated—requires multi-factor 

authentication.’’). 

31See, e.g., Comment Letter of Cory (September 

19, 2023) (‘‘Cory I Comment Letter’’) (‘‘[This is] 

essential to verify the identity and legitimacy of 

those managing financial data, mitigating the risk of 

unauthorized access and fraud’’); Comment Letter 

of XBRL US (November 21, 2023) (‘‘XBRL II 

Comment Letter’’) (‘‘Multi-factor authentication is a 

step forward in increasing EDGAR security and has 

become a standard for most companies.’’); Comment 

Letter of Block Transfer (November 21, 2023) 

(‘‘Block Transfer Comment Letter’’) (‘‘We agree with 

the [Commission’s] position that individual 

accountability through people-based, not 

organization-wide, accounts will lead to greater 

accountability, transparency, and efficiency in the 

market’’). 

32See, e.g., Comment Letter of Society for 

Corporate Governance (August 30, 2024) (‘‘SCG 

Comment Letter’’) (‘‘[I]t appears that some 

Continued 

the dashboard account management 

functionality, allowing filers to manage 

their EDGAR accounts with minimal 

manual interaction with EDGAR. 

If a filer chooses to connect to the 

optional APIs, the filer, through its 

account administrators, must authorize 

at least two technical administrators, 

pursuant to paragraph (d)(3) of Rule 10, 

unless the filer arranges to use the filer 

API tokens and API connections of its 

delegated entity (and the delegated 

entity complies with the requirement to 

maintain at least two technical 

administrators), as requested by 

commenters. Filers choosing to connect 

to the optional APIs must also present 

specified security tokens of limited 

duration in the form of filer API tokens 

and user API tokens, as set forth in the 

EDGAR Filer Manual as amended. 

These token requirements are intended 

to provide security for API connections. 

Filers using their delegated entities’ API 

connections must use their delegated 

entities’ filer API tokens, and 

individuals at those filers must present 

a user API token to interact with the 

APIs to allow identification of the 

individual taking action on EDGAR if 

those APIs require presentation of a user 

API token. 

Filers that do not connect to the 

optional EDGAR APIs will not need to 

comply with these API-related 

requirements and may continue to make 

web-based submissions on EDGAR. 

A. Individual Account Credentials 

Paragraph (d)(1) of Rule 10 as 

proposed and adopted will require that 

a filer only authorize an individual to 

perform functions on the dashboard on 

the filer’s behalf if that individual 

possesses individual account 

credentials, obtained in the manner 

specified in the EDGAR Filer Manual. In 

addition to what was noted in the 

Proposing Release, however, and in 

response to commenter concerns, the 

EDGAR Filer Manual is being amended 

to clarify that individual account 

credentials may not be shared with 

other individuals as the credentials are 

intended to identify the individual who 

takes action on EDGAR. 

As contemplated in the Proposing 

Release, we are amending the EDGAR 

Filer Manual to specify that individual 

account credentials must be obtained 

through Login.gov, a secure sign-in 

service of the U.S. General Services 

Administration.24 Login.gov is used by 

participating Federal agencies, as well 

as State, local, and territorial 

governments to provide a secure login 

process and to allow members of the 

public to use a single account that is 

protected by encryption, multifactor 

authentication, and additional 

safeguards.25 To obtain individual 

account credentials for EDGAR, an 

individual must respond to prompts on 

the Login.gov website to provide an 

email address, create a password, and 

select a multifactor authentication 

option.26 The EDGAR Filer Manual will 

specify that the email address provided 

to Login.gov must match the email 

address the individual has provided or 

intends to provide to EDGAR (during 

enrollment, on amended Form ID, or to 

the relevant account administrator).27

In accord with amended paragraph (d) 

of Rule 10 and the EDGAR Filer Manual, 

and as proposed, all account 

administrators, users, and technical 

administrators must enter their 

individual account credentials and 

complete multifactor authentication to 

log into EDGAR. After entering the 

email address and the password created 

on Login.gov, the individual will be 

prompted to complete the multifactor 

authentication option the individual 

selected when obtaining individual 

account credentials at Login.gov.28

Thus, through Login.gov, multifactor 

authentication for individual accounts 

will be required to access EDGAR. 

The use of multifactor authentication 

aligns with modern security practices, 

such as those set forth in Executive 

Order No. 14028, issued May 12, 2021, 

directing Federal agencies to modernize 

and implement stronger cybersecurity 

standards (‘‘executive order’’),29

including but not limited to the 

deployment of multifactor 

authentication as a foundational 

security tool at Federal agencies. As 

stated in the executive order, the use of 

multifactor authentication enhances 

system security. It further follows digital 

identity guidelines for Federal agencies 

issued by the National Institute of 

Standards and Technology (‘‘NIST’’).30

Multifactor authentication is a widely 

accepted security tool that will improve 

the security of access to EDGAR by 

adding a layer of validation each time 

an individual signs into EDGAR. 

In sum, EDGAR Next will enhance the 

security of filers’ accounts by requiring 

anyone seeking to make a submission on 

EDGAR on behalf of a filer to sign in 

with individual account credentials, 

complete multifactor authentication, be 

authorized by the filer or the filer’s 

account administrator and enter the 

filer’s EDGAR account/central index key 

number (‘‘CIK’’) and central index key 

confirmation code (‘‘CCC’’). 

Commenters generally agreed that 

requiring individual account credentials 

for EDGAR access would improve 

EDGAR security, provide individual 

accountability and, by implementing 

multifactor authentication, align EDGAR 

with current best practices.31

Several commenters expressed 

concerns that the introduction of 

individual account credentials could be 

disruptive or unduly burdensome for 

individuals with reporting obligations 

pursuant to section 16 of the Securities 

Exchange Act of 1934 (‘‘Exchange 

Act’’).32 For the reasons discussed 


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companies have assumed their third-party filing 

agents would handle this major EDGAR overhaul 

without significant disruption or additional work 

by in-house personnel. However, the comment 

letters by filing agents and other vendors suggest 

otherwise.’’); XBRL II Comment Letter (‘‘[W]e do 

not believe the rule proposal adequately addresses 

the needs of Section 16 filers and single individual 

filers [who] will perform their own code 

management.’’). 

33See SCG Comment Letter (‘‘[T]here was also 

concern with respect to the fact that Login.gov is 

used, in many instances, for individuals’ personal 

matters (e.g., Social Security). Using a single 

account for both personal and public filings is 

likely to lead to confusion and hesitation on the 

part of the Section 16 filers. Such individuals may 

not wish to comingle their personal matters with 

their public filing obligations.’’). 

34 Individuals will provide their email addresses 

on Form ID, during enrollment, and to account 

administrators to identify themselves. The 

dashboard will display individuals’ email addresses 

for identification and individuals will receive email 

notifications from EDGAR at their email addresses. 

Therefore, individuals should present to Login.gov 

the email address that they intend to provide to 

EDGAR, that will identify them to others on 

EDGAR, and that they will use to receive 

communications from EDGAR. 

35See amended EDGAR Filer Manual, Volume I, 

at section 3(a). 

36By contrast, if individuals currently have 

Login.gov accounts used in connection with 

EDGAR, they may choose to rely upon those 

existing Login.gov individual account credentials. 

37See, e.g., SCG Comment Letter (‘‘We believe 

that the corporate secretary or legal personnel of the 

registrant—with a Power of Attorney (POA)— 

should be able to complete the process for obtaining 

EDGAR access codes or passphrases without further 

involvement from an individual Section 16 filer.’’); 

XBRL II Comment Letter (‘‘[W]e do not believe the 

rule proposal adequately addresses the needs of 

Section 16 filers and single individual filers will 

perform their own code management.’’). 

38Only one individual (the individual need not 

be an account administrator so long as the filer 

authorizes the individual to enroll) would enroll 

the filer, providing information about authorized 

account administrators during enrollment. After 

enrollment, the account administrators would 

manage the filer’s account on the dashboard, adding 

account administrators, users and technical 

administrators, if connecting to APIs, and 

delegating authority to file, if relevant. 

39See infra text accompanying and following note 

208 (the filer’s CIK, CCC, and EDGAR passphrase 

must be provided to validate the enrollment request 

as legitimate). 

40See SCG Comment Letter (‘‘[Our members] 

expressed concerns about how registrants, Section 

16 insiders, and their filing agents would navigate 

the new MFA process when making filings.’’). 

41See sections II.B.1 and II.B.2. 

42See SCG Comment Letter (‘‘Given that the 

security of Login.gov has been questioned by 

Congress and the Internal Revenue Service has 

expressed reservations about using the platform, the 

Commission should not mandate Login.gov as the 

sole platform that registrants and their Section 16 

filers may use for multi-factor authentication.’’). 

43See ‘‘GSA Misled Customers on Login.gov’s 

Compliance with Digital Identity Standards,’’ Press 

Release, Office of the Inspector General, U.S. 

General Services Administration, available at 

https://www.gsaig.gov/content/gsa-misledcustomers-logingovs-compliance-digital-identitystandards (‘‘GSA knowingly billed IAL2 customer 

agencies over $10 million for services, including 

alleged IAL2 services that did not meet IAL2 

standards.’’) 

below, we do not think that the issues 

raised by these commenters will be 

disruptive or unduly burdensome for 

section 16 filers. One commenter 

asserted that many individuals use 

Login.gov for personal matters and 

suggested that these individuals may 

not wish to use their existing Login.gov 

accounts for EDGAR matters.33 The 

EDGAR Filer Manual as amended will 

require individuals to present an email 

address that matches the email address 

the individual will use in connection 

with EDGAR34 to obtain Login.gov 

individual account credentials for 

EDGAR.35 The email address will 

become the individual’s username for 

Login.gov individual account 

credentials and will be used for 

identification and notification purposes 

on EDGAR. Therefore, if an individual 

currently has a Login.gov account 

created with her personal email address 

and does not intend to use that email 

address in connection with EDGAR 

matters, or is otherwise concerned that 

her personal email address may become 

visible on the EDGAR Filer Management 

dashboard, she should create new 

Login.gov individual account 

credentials with the email address she 

wishes to use in connection with 

EDGAR.36 This email address could be 

the one provided to the individual by 

her employer or that the individual uses 

for business purposes. Individuals can 

continue to use their Login.gov personal 

email address and password for 

personal matters. They will separately 

use the Login.gov individual account 

credentials they created for use on 

EDGAR to log into EDGAR. 

Several commenters further suggested 

that it would be a burden on section 16 

filers to apply for EDGAR access and to 

enroll in EDGAR Next themselves and 

requested that EDGAR permit a 

corporate secretary or legal personnel of 

a registrant to obtain EDGAR access for 

an individual section 16 filer pursuant 

to a power of attorney.37 In response to 

these comments, we clarify that EDGAR 

will permit this. Individuals with 

individual or single-member company 

filer EDGAR accounts may avoid 

obtaining Login.gov individual account 

credentials for EDGAR if they authorize 

an individual at their filing agent or 

other third party to enroll them in 

EDGAR Next and during enrollment 

authorize one or more individuals at 

these entities to act as their account 

administrators.38 For enrollment, 

presentation of a power of attorney for 

the person performing enrollment or 

being authorized as an account 

administrator will not be necessary, 

although we urge all filers to carefully 

coordinate regarding the person they 

will authorize to enroll them. For 

enrollment, the codes required to be 

entered will act as validation of the 

filer’s intent.39

Separately, individual or singlemember company filers who apply for 

access on amended Form ID may 

authorize one or two individuals at their 

filing agents or relevant companies as 

their account administrators on Form 

ID; however, for Form ID, individual or 

single-member company applicants 

must also provide signed, notarized 

powers of attorney to those persons to 

be uploaded to EDGAR together with 

the completed Form ID. Thereafter, the 

filer’s authorized account administrators 

would obtain individual account 

credentials from Login.gov and manage 

the filer’s account on the dashboard. In 

summary, the individual or singlemember company filer would not need 

to obtain Login.gov individual account 

credentials in these circumstances. 

The commenter also expressed 

concerns regarding how section 16 filers 

and others would navigate the 

multifactor authentication process when 

making filings.40 As an initial matter, 

we do not believe that it will be difficult 

for section 16 filers and other 

individuals to navigate the Login.gov 

multifactor authentication process as it 

is substantially the same as the process 

used by numerous financial and other 

websites for verification. It is therefore 

likely that section 16 filers and other 

individuals have experience in 

performing multifactor authentication. 

Alternatively, as discussed above, 

section 16 filers and other individual 

filers may provide notarized powers of 

attorney to authorize account 

administrators to manage filers’ 

accounts and make submissions on 

filers’ behalf, eliminating the need for 

section 16 filers and other individual 

filers to obtain individual account 

credentials or perform multifactor 

authentication themselves.41

The commenter further raised issues 

surrounding the security of Login.gov.42

The matters raised by the commenter 

pertain to Login.gov’s provision of 

identity assurance level 2 (‘‘IAL2’’) 

services,43 which generally require 

gathering certain sensitive personally 

identifiable information such as copies 

of drivers’ licenses, passports, or similar 

documents. EDGAR’s agreement with 

Login.gov, however, is to provide 

identity assurance level 1 (‘‘IAL1’’) 

services, which do not require 

presentation of such sensitive 

personally identifiable information. To 

obtain individual account credentials 

from Login.gov for EDGAR, the 


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44See, e.g., Comment Letter of Donnelley 

Financial Solutions (May 8, 2024) (‘‘DFIN II 

Comment Letter’’) (‘‘[W]e encourage the 

Commission to consider supporting the current 

authentication method for an overlapping period of 

time as an alternative during the EDGAR Next roll 

out. This will help with the transition and 

minimize market disruption.’’); SCG Comment 

Letter (‘‘We agree with DFIN’s suggestion that 

registrants and their Section 16 filers should be 

allowed to use current authentication methods 

during the transition to EDGAR Next to minimize 

disruptions or filing delays.’’) 

45See SCG Comment Letter (‘‘We also ask that the 

Commission consider allowing all Section 16 filers 

to continue to use the existing EDGAR system for 

an additional six months after the enrollment 

period ends, so they do not miss any deadlines 

while the enroll in EDGAR Next.’’) (emphasis in 

original). 

46Further, the commenter appeared to base the 

comment in part upon the assumption that there 

would be a one-month preparation period prior to 

enrollment in EDGAR Next. Instead, the 

Commission is offering filers a six-month 

preparation period which we believe will allay the 

commenter’s expressed concerns. 

47See SCG Comment Letter (‘‘[t]he Commission 

has prudently provided phased-in implementation 

for other rules, such as for XBRL tagging and the 

Form 8–K cybersecurity incident disclosure rules, 

and we believe that a phased-in approach makes 

sense given the hundreds of corporate directors 

who may have to obtain Login.gov accounts and 

then enroll through the EDGAR Next dashboard.’’). 

48 In addition, it is not technically feasible for 

EDGAR to extend legacy filing processes for one 

subset of filers. 

49See DFIN II Comment Letter (‘‘We continue to 

believe that Edgar filers should have the optionality 

to use alternatives to Login.Gov as technology 

offerings evolve.’’); Comment Letter of the 

Investment Company Institute (September 11, 2024) 

(‘‘ICI Comment Letter’’). 

50See SCG Comment Letter (‘‘There will be busy 

filing periods, such as 40 days after the end of a 

fiscal quarter when larger companies make their 

periodic filings, where it would be helpful to have 

alternative platforms for authentication in case 

Login.gov is not available.’’). 

51See Toppan Merrill Comment Letter 

(‘‘Login.gov is a good choice for EDGAR access 

since it was created and is maintained by the 

federal government. It is already utilized by other 

government agencies and some public users.’’). 

52See, e.g., XBRL II Comment Letter (discussing 

situations involving individual filers who sit on 

multiple boards of different issuers); Comment 

Letter of Workiva (November 20, 2023) (‘‘Workiva 

Comment Letter’’) (noting that individual account 

credentials must be managed at an individual level, 

which could cause problems for filers if individuals 

retire or are terminated). 

53See Workiva Comment Letter. 

54See XBRL II Comment Letter. 

individual need only provide her email 

address, create a password, and select a 

multifactor authentication method. The 

security of Login.gov’s provision of IAL1 

services has not been called into 

question, and as noted above, numerous 

Federal and State agencies successfully 

use Login.gov on an ongoing basis. 

Other commenters suggested that 

EDGAR provide filers with the option to 

continue to use a password and CCC 

instead of Login.gov during a transition 

period to EDGAR Next.44 In response to 

these comments, we clarify that from 

March 24, 2025 to September 12, 2025, 

EDGAR will continue to allow 

submissions to be made when the 

password and CCC are presented. One 

commenter asked that the Commission 

allow section 16 filers to continue to log 

into EDGAR under the existing process 

for six months after enrollment ends.45

We are offering the legacy filing process 

for six months from March 24, 2025 

through September 12, 2025, during 

which time filers may also enroll. In 

addition, we are allowing filers to 

continue to enroll on the dashboard for 

an additional three months after the 

compliance date.46 The 12 months that 

precede compliance, consisting of six 

months to prepare for the changes and 

six months to enroll while legacy filing 

processes continue, plus an additional 

three months after compliance to enroll, 

effectively operate as a phased-in 

implementation of the new 

requirements, and permits filers 

multiple means of accessing EDGAR, 

while they coordinate with their filing 

agents and other relevant parties 

regarding how they will manage their 

accounts, and ensures timely 

compliance.47 We considered comments 

regarding offering the legacy filing 

process beyond the transition period, 

but we determined that doing so would 

increase the risk of EDGAR security 

issues arising by delaying the 

implementation of, among other things, 

multifactor authentication and 

individual account credentials.48

Several commenters suggested that 

filers should have the option to use 

alternatives to Login.gov as technology 

evolves.49 Another commenter 

requested alternatives to Login.gov in 

the event the service is unavailable but 

did not suggest what alternatives were 

appropriate.50 Another commenter 

approved of the choice of 

Login.gov.51 Login.gov is a secure 

Federal sign-in service that aligns with 

the modern security practices set forth 

in the executive order and follows the 

digital identity guidelines for Federal 

agencies issued by NIST, as indicated 

above. Using a single secure sign-in 

service strengthens the ability of 

Commission staff to monitor, identify, 

and address login issues related to 

EDGAR. It also increases efficiency in 

terms of EDGAR and filer programming, 

maintenance and customer support and 

ensures that individuals attempting to 

access EDGAR are able to achieve 

similar experiences in the login process. 

Moreover, we are not aware of any 

recurrent Login.gov outage issues that 

necessitate implementing additional 

Federally accepted tools. If in the future 

it is possible to meet the Commission’s 

goals of individual traceability and 

multifactor authentication with 

improved alternative technology, that 

technology will be considered as 

appropriate. EDGAR will be able to 

substitute or add other methods of 

obtaining individual account credentials 

and completing multifactor 

authentication if it is beneficial to do so. 

If the Commission determines to change 

or add methods of authentication to 

EDGAR, we would inform filers in 

advance and specify the changes in the 

EDGAR Filer Manual. 

Some commenters raised concerns 

that requiring individual account 

credentials for EDGAR access could be 

burdensome and confusing in specific 

situations, such as where individuals sit 

on multiple boards of different issuers, 

or an individual retires or is 

terminated.52 The use of individual 

account credentials and multifactor 

authentication is a widely used account 

management process. While we 

acknowledge that requiring individual 

account credentials imposes some 

additional burden in that it interposes a 

new step in the EDGAR access process, 

we do not believe that requiring 

individual account credentials will be 

unduly burdensome or confusing 

because the use of individual user 

permissions is a standard practice in 

software applications and computer 

systems. Moreover, certain examples 

cited by commenters appear to stem 

from some confusion regarding 

dashboard authorization as it pertains to 

individual account credentials. 

Several commenters raised concerns 

about specific scenarios involving 

individual account credentials, such as 

when an individual the filer has 

authorized to act on her behalf retires or 

is terminated,53 or when an individual 

sits on multiple boards.54 In the first 

scenario, an account administrator 

would be able to remove the 

authorization of an individual on the 

dashboard, at which point the 

individual could no longer use her 

individual account credentials to access 

the filer’s account. In the second 

scenario, an individual who sits on 

multiple boards would be able to make 

submissions on any of her EDGAR 

accounts in several different ways. First, 

the individual need not obtain Login.gov 

individual account credentials or 

interact with the dashboard at all if she 

authorized one or more individuals 

employed at her filing agents or other 

relevant companies as her account 

administrators (up to a total of 20) with 

notarized powers of attorney, as 

discussed above. Second, she could log 


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55See, e.g., Workiva Comment Letter (stating that 

delegated entities may try to share individual 

account credentials for a single individual among 

various employees at the delegated entity); XBRL II 

Comment Letter (noting that multifactor 

authentication would protect the Filer Management 

dashboard but would not stop malicious entities 

who somehow obtained the filer’s filer API token 

and user API token from using those tokens). 

56See amended EDGAR Filer Manual, Volume I, 

at section 3(a). 

57See, e.g., Workiva Comment Letter (stating that 

delegated entities may try to share individual 

account credentials for a single individual among 

various employees at the delegated entity). 

58Filers enrolling during the three-month period 

after the compliance date will be required to 

present the CIK, CCC, and passphrase to complete 

enrollment. 

59See Comment Letter of the Securities Industry 

and Financial Markets Association (‘‘SIFMA 

Comment Letter’’) (‘‘[I]t would seem that by 

granting authority to the agent through EDGAR 

Next, there would not be a need for the CCC.’’). 

60Specifically, this will include the filer’s 

account administrators, users, delegated 

administrators, and delegated users. 

61See SCG Comment Letter (‘‘In addition, some 

features of Login.gov (e.g., text or voice MFA 

options) are restricted in certain countries, which 

could impose an added burden on filers based 

outside the United States.’’). 

into the dashboard and delegate to her 

filing agents and other relevant 

companies the authority to make 

submissions on her behalf. Third, the 

individual could log into the dashboard 

and authorize account administrators or 

users of her choice to make submissions 

on her behalf. Fourth, she could be her 

own account administrator or user and 

log into the dashboard with her 

individual account credentials and 

make submissions. We further note that 

for enrollment, she can authorize 

individuals as her account 

administrators without presenting a 

notarized power of attorney, although 

we advise section 16 and other filers to 

carefully plan whom they authorize to 

enroll them in EDGAR Next. Once a filer 

has authorized account administrators, 

the account administrators would make 

submissions on the filer’s behalf and 

otherwise manage the account and 

perform annual confirmation. Given 

these various options and solutions, we 

do not believe that the final 

amendments’ requirements are onerous. 

Commenters also asserted that 

individual account credentials would 

not guarantee EDGAR security, since for 

example individuals could intentionally 

share their individual account 

credentials with unauthorized persons 

or EDGAR could be otherwise 

compromised.55 We acknowledge that 

requiring individual credentials will not 

entirely remove threats to EDGAR 

security, but mandating such credentials 

will improve the overall security of the 

EDGAR system. For example, even if the 

individual account credentials were 

shared, Commission staff and filers 

would know whose credentials were 

shared. Moreover, the use of individual 

account credentials that employ 

multifactor authentication complies 

with current best practices for 

information security at U.S. Federal 

agencies, such as those described in the 

executive order and the NIST digital 

identity guidelines. 

Individual account credentials will 

enhance the ability of filers to securely 

maintain access to their EDGAR 

accounts. Filers currently share access 

codes among multiple individuals, 

making it difficult to track with whom 

the codes are shared or to trace a filing 

to a specific individual. The use of 

individual account credentials should 

enable Commission staff and those with 

filing obligations to determine more 

easily the individuals making specific 

filings on EDGAR, because the personspecific nature of the credentials 

coupled with the individual’s 

multifactor authentication will identify 

individuals associated with EDGAR 

actions—unlike access codes, which are 

tied to a particular EDGAR account 

rather than to an individual.56 Linking 

individuals to the filings they make will 

be particularly useful for Commission 

staff and filers when problematic filings 

are made on EDGAR and will enhance 

the security and integrity of the system. 

Thus, for example, without individual 

account credentials, if an EDGAR filing 

is submitted that appears on its face to 

be materially misleading, Commission 

staff and the filer may confer about the 

contents of the filing, but it may be 

difficult for them to ascertain who 

submitted it given that the filer may 

have widely shared its access codes. 

To address the concern that security 

may be compromised by individuals 

intentionally sharing their individual 

account credentials with unauthorized 

persons,57 we are amending the EDGAR 

Filer Manual to clarify that individual 

account credentials may not be shared 

with other individuals. The Commission 

intends that individual account 

credentials identify the individual who 

takes action on EDGAR and sharing of 

credentials defeats that goal. In 

addition, the sharing of individual 

account credentials among multiple 

individuals undermines the purpose of 

multifactor authentication, which is 

intended to be specific to a known 

individual. 

Use of individual account credentials 

also will provide additional assurance 

that only individuals who have been 

properly authorized by the filer can take 

actions on the filer’s behalf on EDGAR. 

Currently, filers’ interactions with 

EDGAR require the use of several codes. 

Because individual account credentials 

will be used to authenticate individuals 

accessing EDGAR pursuant to Rule 10 as 

amended, the EDGAR password, 

password modification authorization 

code (‘‘PMAC’’), and passphrase will 

not be needed to make submissions after 

the compliance date, as discussed in 

section II.H.58 The historic use of 

several codes with differing functions is 

not in accord with current industry best 

practices. The use of individual account 

credentials aligns more closely with 

modern access processes, including 

multifactor authentication, as set forth 

in the executive order and the NIST 

guidelines discussed above. 

The CCC will continue to function as 

the code required for filing, but those 

seeking to make submissions will also 

need to sign in with individual account 

credentials, complete multifactor 

authentication, and be authorized by the 

filer or an account administrator for the 

filer. Because of these additional 

safeguards, the filer’s CCC will be 

displayed on the dashboard for account 

administrators and users. 

One commenter suggested eliminating 

the CCC as unnecessary given the 

requirement to authorize individuals 

through the dashboard.59 In addition to 

dashboard authorization, EDGAR will 

continue to require the CCC to provide 

additional security, for example, to 

complement API tokens, as well as to 

avoid the need to make additional 

infrastructure and form changes to 

EDGAR at this time. To maintain the 

CCC in a secure environment and 

remove the need for a filer to email or 

circulate the CCC, the CCC will appear 

on the dashboard of individuals 

authorized to make submissions for the 

filer.60 The CCC may be eliminated in 

the future if feasible from a technical 

and security standpoint. 

One commenter indicated that certain 

Login.gov multifactor authentication 

methods are restricted in certain 

countries.61 While we understand that 

not all the methods for multifactor 

authentication on Login.gov may be 

available to those in certain countries, 

we note that Login.gov offers 

individuals several different 

authentication methods, including a 

security key, certain Federal 

Government employee or military cards, 

authentication applications, biometric 

(face or fingerprint) verification, text 

message/SMS or telephone call, and 

backup codes. Further, there are several 

authentication applications accepted by 


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62Current Login.gov authentication applications 

include Android and iOS options (Google 

Authenticator, Authy, LastPass, 1Password), 

Windows and Mac apps (1Password and OTP 

Manager), and Chrome extensions (Authenticator). 

See generally Login.gov, Authentication Options at 

https://www.login.gov/help/get-started/ 

authentication-options/. 63See Block Transfer Comment Letter (‘‘[W]e 

respectfully submit to the Commission that 

Login.gov might present material benefits to issuers 

if it replaced the proposed security interface using 

EDGAR Next API keys.’’). 64As defined in amended Rule 11 and amended 

Form ID, a ‘‘single-member company’’ will be a 

company that has a single individual who acts as 

the sole equity holder, director, and officer (or, in 

the case of an entity without directors and officers, 

holds position(s) performing similar activities as a 

director and officer). 

65Minor revisions to paragraph (d)(2) as proposed 

were made to the paragraph as adopted to clarify 

that each individual or single-member company 

electronic filer must authorize and maintain at least 

one individual as an account administrator to 

manage its EDGAR account. 

66See the EDGAR Next page on SEC.gov for 

guidance regarding actions on the dashboard. 

Login.gov.62 Individuals need only 

choose one method available to them. 

Therefore, we expect that filers in such 

countries will be able to choose an 

alternative method on Login.gov to 

satisfy the multifactor authentication 

requirement. 

Another commenter asserted that in 

lieu of individual account credentials 

and multifactor authentication, as 

contemplated in the Proposing Release, 

Login.gov should allow EDGAR 

authentication via EDGAR Next API 

keys.63 API keys alone, however, do not 

provide the security assurances of 

multifactor authentication. 

B. Individual Roles: Account 

Administrator, User, Technical 

Administrator 

Paragraph (d)(2) of Rule 10 as 

proposed and adopted requires each 

filer to authorize and maintain at least 

two individuals with individual account 

credentials as account administrators to 

manage the filer’s EDGAR account and 

to make submissions on EDGAR on 

behalf of the filer, unless the filer is an 

individual or single-member 

company,64 in which case the filer will 

be required to authorize and maintain at 

least one individual with individual 

account credentials as an account 

administrator.65

Account administrators, acting on 

behalf of the filer, may authorize and 

de-authorize individuals with 

individual account credentials as users, 

additional account administrators, or 

technical administrators for the filer, as 

needed, using the dashboard (or the 

optional APIs that will enable filers to 

access much of the dashboard’s 

functionality via machine-to-machine 

connections).66 This process is 

illustrated in diagram 1 below. 

An individual could be authorized to 

perform more than one role for a filer. 

For example, one individual could be 

both an account administrator and a 

technical administrator, or one 

individual could be both a technical 

administrator and a user. An account 

administrator could not be a user, 

however, because account 

administrators can perform all the 

functions of a user themselves, 

including making submissions on 

EDGAR. Analogous roles will exist at 

delegated entities. The key functions 

that could be performed by each role are 

illustrated in diagram 2 below. 


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67See, e.g., Cory I Comment Letter (‘‘One of the 

cornerstones of EDGAR Next is the requirement for 

filers to designate account administrators. . . . In 

an era of machine-driven manipulation, this human 

oversight is crucial for detecting and preventing 

illicit activities.’’); Toppan Merrill Comment Letter 

(‘‘Yes, a required account Administrator [sic] role 

is necessary for every filer (every CIK). Ideally two 

Administrators [sic] should be required.’’). 

68Technical administrators will serve as the 

Commission staff’s points of contact regarding the 

filer’s use of the APIs. See infra section II.B.3.a. 69See Workiva Comment Letter (‘‘The current 

POC is likely a different type of staff, such as legal 

staff, from the administrators who are likely to be 

reporting or services staff.’’). 70See Workiva Comment Letter (‘‘We further 

suggest automatically enrolling the current POC as 

super administrator. The super administrator 

should be contacted before any severe action on the 

EDGAR account is taken, such as account 

deactivation.’’). 

1. Account Administrators 

Paragraphs (d)(4), (5), and (6) of Rule 

10 as proposed and adopted require that 

the filer, through its account 

administrators, maintain accurate and 

current information on EDGAR 

concerning the filer’s account and 

confirm such information annually, and 

securely maintain information relevant 

to the ability to access the filer’s EDGAR 

account, including but not limited to 

access through optional APIs. 

Commenters broadly supported the 

implementation of account 

administrators to manage filers’ 

accounts,67 although commenters raised 

concerns about specific issues as 

discussed below. 

Under EDGAR Next, each filer will be 

responsible, through its account 

administrators, for the security of the 

filer’s EDGAR account and the accuracy 

of the filer’s information on EDGAR. 

Account administrators will manage the 

filer’s account on the dashboard or 

through optional APIs replicating most 

dashboard functionality in machine-tomachine connections. The filer will be 

required, through its account 

administrators, to perform annual 

confirmation on the dashboard. Account 

administrators will also be able to use 

the dashboard or optional APIs to add 

and remove users, account 

administrators and technical 

administrators (including removing 

themselves as an account 

administrator); create and edit groups of 

users; delegate filing authority to other 

EDGAR accounts and remove 

delegation; generate a new CCC; and 

receive notifications regarding 

significant events affecting the account 

(notifications will also be emailed to the 

account administrator’s email address 

provided to EDGAR). Further, account 

administrators will be able to make 

submissions on behalf of the filer on 

EDGAR, which will allow filers to 

manage their accounts and make 

submissions through a limited number 

of individuals, if they choose. Each 

account administrator will be co-equal, 

possessing the same authority and 

responsibility to manage the filer’s 

EDGAR account. All actions required to 

be performed by account administrators 

can be performed by any of them 

individually and will not require joint 

action. 

In addition, account administrators 

will serve as the points of contact for 

questions from Commission staff 

regarding the filer’s account.68 One 

commenter suggested that existing filers 

with a single EDGAR point of contact 

for information, inquiries, and access 

codes (‘‘EDGAR POC’’) typically rely 

upon legal staff, whereas under EDGAR 

Next those filers may choose to 

authorize, for example, services staff as 

account administrators.69 The 

commenter stated that the EDGAR POC 

for existing filers should be 

automatically enrolled as a ‘‘super 

administrator’’ for the filer and notified 

regarding significant events affecting the 

account.70 Because filers may wish to 

designate a single account administrator 

as a primary EDGAR POC, EDGAR will 

offer an option to allow account 

administrators to designate one account 

administrator as the filer’s EDGAR POC. 

EDGAR will by default designate the 

first account administrator listed on 

Form ID or an existing filer’s enrollment 

as the filer’s EDGAR POC. The filer, 

through its account administrator, may 


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71See, e.g., XBRL II Comment Letter (‘‘There 

should be a mechanism in the filing management 

dashboard where the company (e.g. technical 

admin) can identify and contact their 

administrators . . .’’); Workiva Comment Letter 

(‘‘[A] a user may not necessarily know who the 

administrators are to contact. We suggest adding a 

‘‘Contact Administrator’’ function in the EDGAR 

Dashboard to facilitate.’’). 

72A separate process of enrollment will be 

employed to transition existing filers, as discussed 

in section II.H. 

73See, e.g., Comment Letter of Donnelley 

Financial Services (November 21, 2023) (‘‘DFIN 

Comment Letter’’) (‘‘[In addition to account 

administrators,] any ‘‘User’’ should also be allowed 

to submit a Form ID. The account administrator(s) 

might be busy, unavailable, or decide it’s a menial 

task.’’); Workiva Comment Letter (‘‘[I]t is not 

necessary to require an account administrator to 

submit the Form ID. A user should also be able to 

submit the Form ID. The Form ID is already 

required to be signed and notarized by authorized 

personnel. . . . A user is adequate for 

submission.’’). 

74The amended EDGAR Filer Manual specifies 

that an ‘‘authorized individual’’ must sign a power 

of attorney on behalf of the filer in this context. See 

amended EDGAR Filer Manual, Volume I, at section 

3. 

75See, e.g., Toppan Merrill Comment Letter (‘‘We 

support the proposal to have the initial account 

administrator require a notarized power of attorney, 

if applicable.’’); DFIN Comment Letter (‘‘[I]f the 

account administrator is an employee of the filer’s 

affiliate, they should not be required to be 

authenticated via a notarized power of attorney.’’); 

Workiva Comment Letter (‘‘We believe that a 

notarized power of attorney should not be required 

to add an employee of another entity as an 

administrator. This could significantly increase the 

burden for the individual reporting owners. . . .’’). 

76See Workiva Comment Letter (‘‘In addition, 

since the power of attorney is only needed initially, 

and once an administrator is added to the EDGAR 

Dashboard additional administrators can be added 

without a new power of attorney; it seems 

inconsistent and somewhat arbitrary that there is a 

higher threshold for the first one.’’). 

change its EDGAR POC thereafter on the 

dashboard. Commission staff may 

contact the filer’s other account 

administrators if, for example, the 

EDGAR POC cannot be reached or is 

nonresponsive. The EDGAR POC will 

not be a ‘‘super administrator,’’ as 

suggested by the commenter, however, 

and each account administrator will 

have co-equal authority to take action 

on EDGAR as well as to receive notices 

of actions on the filer’s account. Other 

than acting as a central point of contact, 

the EDGAR POC will not differ in any 

other respect from other account 

administrators. 

Several commenters stated that the 

dashboard should provide a mechanism 

for authorized users or other interested 

parties to easily identify and contact the 

filer’s account administrators.71 The 

dashboard will be enhanced to provide 

this functionality. In this regard, 

account administrators will also serve as 

points of contact for technical 

administrators, users and delegated 

entities. 

a. Filer Authorization of Account 

Administrators 

As proposed and adopted, applicants 

for EDGAR access will designate on 

amended Form ID the individuals that 

the filer authorizes as account 

administrators.72 Pursuant to paragraph 

(d)(1) of Rule 10 as proposed and 

adopted, the filer can only authorize 

individuals as account administrators if 

those individuals obtain individual 

account credentials in the manner 

specified in the EDGAR Filer Manual. 

We are adopting the amendments to 

Form ID largely as proposed, as 

discussed in section II.F.3. In response 

to commenter concerns, however, it will 

not be necessary for Form ID to be 

completed or submitted by one of the 

applicant’s prospective account 

administrators, as contemplated in the 

Proposing Release. This change will 

allow a filer to choose who will 

complete and submit Form ID so long as 

the filer complies with the continued 

requirement that the form be signed by 

the filer’s authorized individual, as that 

term is defined in Rule 11 of Regulation 

S–T and Volume I of the EDGAR Filer 

Manual, and that the signature is 

notarized. Additionally, given 

commenter concerns that asset-backed 

securities (‘‘ABS’’) issuing entities that 

make ‘‘Request Asset-Backed Securities 

(ABS) Issuing Entities Creation’’ 

submissions (‘‘ABSCOMP’’ 

submissions’’) should have their 

account information automatically 

copied to any serial companies, EDGAR 

will allow for new serial companies 

requested to be created via the 

ABSCOMP process to automatically 

inherit all dashboard information 

associated with the ABS issuing entity 

that made the ABSCOMP submission. 

Consistent with current requirements, 

an applicant must complete Form ID 

and electronically submit it, and also 

upload a copy of the completed Form ID 

signed by an authorized individual of 

the applicant with the signature 

notarized. As a departure from what we 

contemplated in the Proposing Release, 

it will not be necessary for Form ID to 

be completed or submitted by one of the 

applicant’s prospective account 

administrators. Some commenters were 

concerned that requiring an account 

administrator to complete and submit 

Form ID would be burdensome and 

unnecessarily restrictive.73 We 

understand that providing flexibility in 

terms of who completes and submits 

Form ID will facilitate the application 

process. 

As contemplated in the proposal, 

entity applicants will be able to 

authorize as account administrators 

either (i) individuals employed at the 

filer or an affiliate of the filer or (ii) any 

other individual provided the filer 

submits a notarized power of attorney 

authorizing that individual to be its 

account administrator.74 Individual 

applicants will be able to authorize as 

account administrators either (i) 

themselves or (ii) any other individual 

provided the filer submits a notarized 

power of attorney authorizing that 

individual as account administrator. 

Commenters provided mixed feedback 

on this issue, with one supporting the 

notarization requirement as 

contemplated in the proposal; another 

advancing that the requirement should 

not apply to employees of affiliates; and 

another expressing concern that the 

notarization requirement as a whole 

would be unduly burdensome.75

Although we acknowledge the added 

time and effort required to obtain a 

notarized power of attorney, the process 

is relatively straightforward, analogous 

to the current process of notarization of 

the authorized individual signature on 

Form ID, and not unduly time 

consuming. Moreover, the process will 

provide greater assurance that a filer 

indeed intends to authorize an 

individual not employed at the filer or 

an affiliate of the filer to manage the 

filer’s EDGAR account. We therefore are 

implementing the notarized power of 

attorney requirements as proposed, and 

the amended Form ID and EDGAR Filer 

Manual will reflect those requirements. 

A commenter questioned why the 

requirement to present a notarized 

power of attorney to authorize an 

employee of an entity other than the 

filer as account administrator on Form 

ID is needed when authorization of 

additional account administrators 

through the dashboard does not require 

notarization.76 The requirement to 

present a notarized power of attorney to 

authorize individuals who are not 

employed at the applicant or an affiliate 

as account administrators on Form ID 

provides Commission staff—who review 

each Form ID to determine whether 

access should be granted—a means of 

confirming that these individuals are 

indeed authorized on behalf of the 

applicant. The requirement lessens the 

risk that unauthorized persons will 

attempt to establish or access an account 

by submitting a false or misleading 

Form ID. We did not include a 

notarization requirement for account 

administrators added through the 

dashboard, because once Commission 

staff grant access to EDGAR, filers are 

responsible, through their account 

administrators, for the security of the 


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77See DFIN Comment Letter (‘‘[T]he Account 

Administrator and information from the ABS 

Issuer’s Account Administrator should be copied to 

the new serial account, after which, any changes 

can be made.’’); Cadwalader, Wickersham & Taft 

LLP Comment Letter (November 21, 2023) 

(‘‘Cadwalader Comment Letter’’) (‘‘For [commercial 

mortgage-backed securities] issuers, allowing 

automatic inheritance by the individual serial trusts 

of all information from the depositor would be the 

most efficient approach.’’). 

78See Toppan Merrill Comment Letter (‘‘The 

proposed functionality for an ABS account 

administrator to access the dashboard for serial 

companies could be utilized for other issuers who 

have a related structure with multiple entities . . . 

[i]ncluding . . . corporate issuers with coregistrants [and] beneficial ownership reporting 

filers (e.g., 144, SC 13D, SC 13G, and section 16 

filers), and ABS issuers . . . . If the existing option 

to create a serial company by the ‘ABSCOMP’ 

process is available in EDGAR Next functionality 

that will be sufficient for ABS entities to manage 

creating new CIKs.’’). 

79See, e.g., Toppan Merrill Comment Letter 

(‘‘Yes, we believe requiring two account 

administrators is appropriate.’’); Workiva Comment 

Letter (‘‘We believe at least two account 

administrators for filing entities (other than singlemember companies) is appropriate.’’). 

80See Workiva Comment Letter (‘‘For individuals 

and single-member companies, please clarify if the 

one minimum administrator must be the individual 

himself or herself.’’). 

81See Toppan Merrill Comment Letter (‘‘We 

suggest that additional warnings are provided when 

the ‘single-member companies’ selection is made. 

The warning should alert that access to the filer 

management website will be lost if the single 

administrator is no longer available, which may 

lead to loss of ability to file on EDGAR’’). 

filer’s EDGAR account and the accuracy 

of the filer’s information on EDGAR. 

Filers can take the additional steps they 

determine are necessary to comply with 

the Rule 10 and EDGAR Filer Manual 

requirements to secure their accounts. 

We also received several comments 

regarding the authorization of account 

administrators in situations unique to 

specific types of filers. One commenter 

recommended that account 

administrators associated with ABS 

issuing entities that make ABSCOMP 

submissions should automatically be 

copied to any serial companies created 

as a result of that submission, and 

another commenter suggested that all 

account information associated with the 

ABS issuing entity should be 

automatically copied over to the newly 

created serial companies.77 Up to 100 

serial companies can be created via a 

single ABSCOMP submission, and we 

recognize that it would be time 

consuming to require identical 

addresses, account administrators, and 

other information to be manually 

inputted for each serial company. 

Consequently, the ABSCOMP process 

will be available in the dashboard, and 

new serial companies requested to be 

created via that process will 

automatically inherit all dashboard 

information (e.g., contact information, 

account administrators, users, technical 

administrators, and delegations) 

associated with the ABS issuing entity 

that made the ABSCOMP submission. 

Changes to the inherited information 

could be made after creation of the new 

serial companies. For example, 

individuals could be added or removed 

on the dashboard by the serial 

company’s account administrators, 

while filer information such as name, 

address, and State of incorporation 

could be updated via Company Update 

submissions (‘‘COUPDATs’’), consistent 

with current practice. 

Another commenter indicated that 

making the ABSCOMP process available 

in the dashboard would be sufficient for 

ABS entities to manage the creation of 

new EDGAR accounts and suggested 

that similar functionality should be 

provided for other issuers that have a 

structure with multiple related parties, 

such as co-registrants and beneficial 

ownership reporting filers, to allow 

them to more easily manage EDGAR 

accounts.78 We have determined not to 

extend the above-described ABSCOMP 

process to include other entities such as 

investment companies and coregistrants, because ABSCOMP is 

unique in allowing rapid creation of 

multiple serial companies via a single 

transaction, predicated in part upon the 

serial companies all being largely 

identical (e.g., contact information, 

account administrators, etc.). In 

contrast, although beneficial ownership 

reporting filers and co-registrants may 

be related parties, each of these filers 

typically possesses separate filerspecific information such as name, 

address, and contact information. 

Furthermore, these filers could have 

separate reporting obligations (for 

example, beneficial ownership reporting 

filers in the context of different issuers, 

and co-registrants in the context of 

different securities offerings). Thus, in 

the EDGAR Next framework, each of 

these filers presumably would want to 

authorize her own account 

administrators, and it would be 

inappropriate to automatically assign all 

such filers the same account 

administrators. In addition, the optional 

APIs being added to EDGAR Next 

should serve to mitigate any additional 

burdens for these filers by allowing the 

filers to rapidly add account 

administrators and make other changes 

as necessary, as discussed further in 

section II.E below. 

The Proposing Release also requested 

comment on whether elimination of the 

ability of ABS issuers to create new ABS 

serial companies ‘‘on the fly’’ when 

filing a 424H submission would cause 

any problems, given that the EDGAR 

Next framework would continue to 

allow ABS issuers to request creation of 

serial companies via ABSCOMP 

submissions. We received no comments 

on this issue. EDGAR data indicates that 

ABS issuers have not used the ‘‘on the 

fly’’ process for several years, and 

accordingly EDGAR will be updated to 

remove the ability of ABS issuers to 

create new serial companies ‘‘on the 

fly.’’ 

b. Number of Account Administrators 

As contemplated in the proposal, 

paragraph (d)(2) of Rule 10 as adopted 

requires filers who are individuals or 

single-member companies to authorize 

and maintain at least one account 

administrator; all other filers will be 

required to authorize and maintain at 

least two account administrators. The 

maximum number of account 

administrators on the dashboard is 20. 

Although individuals and singlemember companies are only required to 

authorize and maintain at least one 

account administrator, we encourage 

them to authorize additional account 

administrators in the event the sole 

account administrator becomes 

unavailable to manage the account. 

Commenters generally supported the 

proposed requirement to maintain a 

minimum of two account 

administrators,79 although various 

commenters recommended technical 

changes or additional clarification. One 

commenter sought clarification 

regarding whether, for single-member 

companies and individuals, the required 

account administrator must be the 

single member or individual herself.80

Paragraph (d)(2) of Rule 10 does not 

require this. Filers will have the 

flexibility to authorize individuals at 

their filing agents or other third parties 

as account administrators, so long as 

they provide notarized powers of 

attorney authorizing those individuals. 

Another commenter requested that an 

additional warning be provided when 

the ‘‘single-member company’’ selection 

is made to alert the filer that she would 

be unable to manage her EDGAR 

account if the single account 

administrator is not available.81 A 

warning notice will be added to the 

online version of Form ID as requested 

if the ‘‘single-member company’’ 

selection is made. Separately, although 

single-member companies will only be 

required to have a single account 

administrator, we encourage filers to 

authorize additional account 

administrators on the dashboard as 


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82 In this case, the filer would select the option 

on Form ID indicating that it had lost electronic 

access to its existing CIK account. This option also 

encompasses other scenarios, such as when a filer 

loses access due to failure to satisfy required annual 

confirmation requirements. See infra note 90. 

83See, e.g., XBRL II Comment Letter (‘‘As well as 

requiring a minimum of two administrators . . . we 

do think notification is appropriate. Alerting other 

administrators when an administrator is added or 

leaves will improve the ability for the network to 

react to administrator changes.’’); DFIN Comment 

letter (‘‘We also think that a filer should be notified 

when additional account administrators are added 

or removed.’’). 84See XBRL II Comment Letter (‘‘Addition 

without consent should be allowed, to manage 

emergencies that may arise. . . We understand that 

there is still a potential risk with rogue actors at 

firms, but firms are managing the risk of rogue actor 

employees today and should be left to manage that 

problem in regard to EDGAR Next.’’); Workiva 

Comment Letter (‘‘We believe the filer’s consent is 

not necessary as long as the filer has an 

administrator that will be notified and can take 

additional action if needed.’’). 

necessary (up to a maximum of 20) to 

ensure that an account administrator is 

always available to take necessary 

actions. 

Requiring most filers to authorize at 

least two account administrators will 

increase the ability of filers to manage 

their EDGAR accounts without 

interruption. Thus, if an account 

administrator unexpectedly resigns or 

otherwise ceases to be available to 

manage the filer’s account, the 

remaining account administrators will 

continue to manage the account and 

will be able to authorize additional 

account administrators. If the account 

administrator who seeks to resign is one 

of the required two account 

administrators for an entity filer, then 

that account administrator could not be 

removed from the filer’s EDGAR 

account unless the filer first added 

another account administrator through 

the dashboard to meet the required 

minimum of two account 

administrators. For example, if there are 

two account administrators for the 

account and one unexpectedly becomes 

unavailable, the remaining account 

administrator could add another 

account administrator to the account 

and then remove the unavailable 

individual. For individual and singlemember company filers, at least one 

account administrator will always be 

required because those filers typically 

consist of only one individual. A 

dashboard limit of 20 account 

administrators should be sufficient to 

allow for management of large accounts, 

while avoiding the confusion that a 

larger number of account administrators 

might cause. 

We encourage filers to authorize more 

than the minimum number of account 

administrators, if possible, because if all 

account administrators for a filer cease 

to be available to manage the filer’s 

account, the filer will be required to 

submit a new Form ID to authorize new 

account administrators.82

c. Account Administrator Authorization 

and Removal of Users, Technical 

Administrators, and Other Account 

Administrators 

An account administrator will be able 

to add or remove an individual as a 

user, account administrator, or technical 

administrator for an EDGAR account 

through the dashboard, as discussed in 

the Proposing Release. An account 

administrator will ‘‘add’’ the individual 

on the dashboard and EDGAR will send 

an invitation to the individual by email 

and through the dashboard (if the 

individual has a role for any filer on 

EDGAR) indicating that the account 

administrator for the filer sought to add 

her to the filer’s account in a particular 

role or roles. The individual must 

accept the invitation, either through the 

email or on the dashboard, to accept the 

new role(s) and become authorized in 

those role(s) for the filer. The same 

process of invitation both through email 

and the dashboard applies to all 

invitations, and the individual receiving 

the invitation may accept via the email 

or the dashboard invitation. 

Commenters expressed general 

support for notifying filers when an 

account administrator removes or adds 

another account administrator.83 Some 

commenters, however, expressed the 

view that while filer notification would 

be appropriate, filer consent is not 

necessary and should not be required.84

In response to this point, EDGAR will be 

enhanced to provide notifications to all 

relevant account administrators through 

the dashboard and by email when 

individuals are added or removed from 

an account, or the roles for those 

individuals are changed. The discussion 

of this matter in the Proposing Release 

did not indicate that filers would need 

to consent to these changes, and EDGAR 

will not require such consent for the 

changes to be effective. These 

notifications will allow account 

administrators to monitor relevant 

activity while minimizing the delay that 

might result from approval of each 

individual action. 

d. Annual Confirmation 

Paragraph (d)(4) of Rule 10 as 

proposed and adopted requires each 

filer to perform an annual confirmation 

on EDGAR that all the filer’s users, 

account administrators, technical 

administrators, and delegated entities 

are authorized by the filer to act on its 

behalf, and that all information related 

to the filer reflected on the filer’s 

dashboard is accurate. Account 

administrators will act for the filer to 

carry out this function. Annual 

confirmation will assist the filer in 

tracking those authorized to file on 

EDGAR and will provide an opportunity 

for account administrators to confirm 

the accuracy of those individuals and 

delegated entities associated with the 

filer and to remove those no longer 

authorized. In a change from what was 

contemplated in the Proposing Release, 

in response to commenter concerns, we 

are extending the grace period before 

account deactivation for filers that fail 

to timely perform annual confirmation 

from two weeks (as discussed in the 

Proposing Release) to three months 

following the annual confirmation 

deadline. During the three-month grace 

period, filers will be able to continue to 

make submissions and take actions on 

EDGAR as usual, while account 

administrators will receive notices 

reminding them to complete annual 

confirmation by the end of the grace 

period, as discussed in more detail 

below. 

To provide flexibility to filers, EDGAR 

will allow account administrators to 

select one of four quarterly dates as the 

filer’s ongoing confirmation deadline: 

March 31, June 30, September 30, and 

December 31 (or the next business day 

if the date falls upon a weekend or 

holiday when EDGAR is not operating). 

An account administrator need not wait 

until the deadline to confirm. An 

account administrator may choose to 

perform confirmation at an earlier date 

within the quarter when confirmation is 

due. Further, an account administrator 

will be able to perform confirmation on 

any date in a quarter earlier than the 

quarter of the current deadline, thereby 

changing the quarter when confirmation 

is due going forward. Confirmation in 

an earlier quarter will result in a 

confirmation deadline one year after the 

end of the quarter in which the early 

confirmation occurred. For example, if a 

December 31 confirmation deadline 

were selected by the account 

administrator for the initial annual 

confirmation, but the account 

administrator submitted the 

confirmation for the following year in 

August, the filer’s annual confirmation 

deadline for the next year would be 

September 30 (or the next business day, 

if the date fell upon a weekend or 

holiday when EDGAR was not 

operating). 

Commenters generally expressed 

support for account administrator 

performance of annual confirmation as 

contemplated in the Proposing 


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85See, e.g., DFIN Comment Letter (‘‘The proposed 

annual confirmation requirement is sufficient’’); 

Cadwalader Comment Letter (for annual 

confirmation for serial trusts, ‘‘We believe that such 

an approach is both appropriate and efficient.’’); 

Toppan Merrill Comment Letter (asserting that the 

annual confirmation requirement would create 

additional burden for filers but expressing 

agreement with the requirement as proposed.). 

86Compare Block Transfer Comment Letter (‘‘. . . 

the benefits of the security measure proposed . . . 

would outweigh the significant burden it would 

impose on filers’ internal controls.’’) with Comment 

Letter of Uchi (September 13, 2023) (requesting a 

‘‘3 or 6 month renewal check for the company to 

ensure all administrative accounts assigned to the 

company are still valid as employees incase [sic] of 

termination while maintaining administrative 

access to said company filing permissions.’’); 

Comment Letter of Alexander (September 15, 2023) 

(same). 

87See Cadwalader Comment Letter (‘‘On an 

operational level, we do not expect individual serial 

trusts to have account administrators, technical 

administrators, users or delegated entities that are 

not also performing the same functions for the 

depositor, although the depositor may have certain 

additional account administrators, technical 

administrators, users or delegated entities who are 

not assigned to all of the related serial trusts. 

Therefore, depositor-level confirmation of its 

authorized parties would also encompass all 

individuals assigned roles with respect to each 

individual serial trust.’’); Toppan Merrill Comment 

Letter (responding to a request for comment 

regarding whether bulk confirmations should be 

permitted by stating ‘‘Yes, affiliated filers with the 

same administrators, users, delegations, and 

corporate and contact information should be 

allowed similar functionality[.]’’). 

88See supra text following note 52. 

89See, e.g., Workiva Comment Letter (‘‘We 

strongly recommend temporary suspension over 

account deactivation. . . . Failure to confirm 

annually may signal a problem occurred in the 

notification process rather than the filer being no 

longer in control of the account. . . . Deactivation 

should only occur after six months of 

suspension.’’); XBRL II Comment Letter (‘‘The 

annual confirmation requirement will create a 

significant additional burden for filers that use a 

filing agent’s SEC credentials, in particular for those 

filers who make sporadic submissions such as 

Section 16 filers. . . . We encourage the 

Commission to consider imposing a temporary 2- 

week suspension if the confirmation requirement is 

not met before deactivating a nd removing 

information from an existing account.’’). 90 In this case, the filer would select the option 

on Form ID indicating that it had lost electronic 

access to its existing CIK account. This option 

would also encompass other scenarios, such as 

when all the filer’s account administrators cease to 

be available to manage the filer’s account. See supra 

note 82. 

Release.85 One commenter asserted that 

annual confirmations would be overly 

burdensome, while two other 

commenters recommended that 

confirmations be performed more 

frequently than annually, such as 

quarterly or every six months.86 We 

believe that annual confirmation strikes 

the appropriate balance of periodically 

ensuring the accuracy of filers’ 

information in EDGAR, without unduly 

burdening filers and account 

administrators. To facilitate the 

confirmation process and remind 

account administrators about 

confirmation deadlines, as discussed in 

the Proposing Release, EDGAR will 

provide periodic notices to account 

administrators both by email and on the 

dashboard regarding each upcoming 

confirmation deadline, a notice of 

completion of confirmation, and 

numerous notices of failure to timely 

confirm prior to deactivation of the 

account. Specifically, prior to the 

confirmation deadline, EDGAR will 

send notices six weeks, three weeks and 

each of the five business days leading 

up to the confirmation deadline.If filers 

fail to perform annual confirmation on 

or before the confirmation deadline, 

EDGAR will send reminders to all 

account administrators for the filer each 

business day after the confirmation 

deadline until expiration of the threemonth grace period. EDGAR will also 

offer an optional API to allow filers to 

programmatically check filing 

credentials and upcoming confirmation 

deadlines. 

Several commenters suggested that 

the Commission allow bulk annual 

confirmations to be performed for 

related EDGAR accounts, such as 

accounts that share the same 

administrators, users, delegations, and 

corporate and contact information.87 As 

discussed above, related EDGAR 

accounts (such as co-registrant) may 

often have different dashboard 

information, which suggests that bulk 

confirmation is not appropriate given 

the need to separately review and 

confirm the accuracy of dashboard 

information for each filer.88 We are 

further concerned that account 

administrators might inadvertently 

perform a bulk confirmation of 

hundreds of filers without carefully 

reviewing each filer’s information. To 

ensure the accuracy of the filer’s 

information on EDGAR, a filer must, 

through its account administrator, 

carefully inspect the information on the 

filer’s dashboard. As a result, bulk 

confirmation will not be permitted. 

Filers may achieve efficiencies in the 

confirmation process by leveraging 

optional APIs that will allow them to 

rapidly add and remove individuals, 

change authorized roles, and perform 

delegations to ensure the accuracy of 

information on the dashboard prior to 

performing confirmation. For example, 

in preparation for confirmation, a filer 

could view all individuals authorized to 

act on behalf of the filer through an API 

being made available for that purpose. If 

updates to the roles or authorization of 

individuals were needed, the filer could 

add and remove individuals and change 

individuals’ roles through APIs being 

made available for those purposes. 

As noted above, the Proposing Release 

contemplated a two-week grace period 

for filers that failed to perform annual 

confirmation. Some commenters stated 

that the annual confirmation 

requirement would impose a significant 

additional burden on filers and 

recommended that filers should initially 

be suspended before they are 

deactivated, while others requested an 

extension of the grace period before 

deactivating the filer’s access.89 After 

considering these comments, we will 

expand from two weeks to three months 

the grace period following a missed 

confirmation deadline, during which 

the filer will be able to continue to make 

submissions and take actions on the 

filer’s account as usual and the filer’s 

account administrators will receive a 

final series of notices reminding them to 

complete annual confirmation. If no 

account administrator performs the 

annual confirmation by the end of the 

three-month grace period, EDGAR will 

deactivate the filer’s access and the filer 

will be required to submit a new Form 

ID application to request access to file 

on its account.90 If Commission staff 

grant the Form ID, the filer will 

continue to have the same account 

number/CIK previously assigned and its 

filing history will be maintained. The 

filer’s account administrators listed on 

Form ID, however, will need to invite 

through the dashboard, as if to a new 

account, additional account 

administrators, and any technical 

administrators and users, and delegate 

authority to file, if relevant. Although 

the need to reapply for access and in 

particular the need to invite account 

administrators, users, and technical 

administrators anew will impose an 

additional burden on filers, failure to 

perform an annual confirmation, 

particularly after receipt of multiple 

notices, could signal that the filer is no 

longer managing or controlling the 

account. Removing individuals from the 

filer’s account upon deactivation 

safeguards information regarding 

individuals whose information is listed 

on the filer’s dashboard. For example, if 

someone other than the original filer’s 

account administrators submitted a 

Form ID application for access to the 

account, and the original account 

administrators did not respond to 

Commission staff inquiries regarding the 

Form ID, the process outlined above 

will prevent the new account holder 

from accessing the names, addresses, 

and contact information of the 

individuals formerly associated with the 

account. Collectively, this framework 

will provide filers that inadvertently 


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91See Toppan Merrill Comment Letter (‘‘The 

system should allow for multiple users to be 

uploaded at the same time. This will ensure that 

users groups can be built quickly and efficiently.’’) 

92See Toppan Merrill Comment Letter (‘‘User 

group functionality would be improved by allowing 

for wildcard searches to include first and last 

names. Currently, the search disregards any name 

after the space between the first and last name.’’). 

93Commenters were generally supportive of the 

user role. See comments by Toppan Merrill, DFIN, 

SIFMA, and XBRL II. 

94An accession number is a unique identifier 

assigned automatically to EDGAR submissions for 

tracking and reference purposes. The first 10 digits 

are intended to represent the CIK of the entity 

making the submission, which may be an entity 

with reporting obligations or a third party (such as 

a filing agent). 

95See SIFMA Comment Letter (‘‘We recommend 

that the SEC provide functionality that would allow 

retail clients to directly authorize their financial 

advisers (i.e., registered representatives of the 

broker-dealer) to act as a ‘user’ for the sole purpose 

of filing the Form 144s.’’). 

96See supra note 75 and accompanying and 

following text (discussing notarization requirements 

for individuals who are not employed at the filer 

or an affiliate of the filer). 

97See Workiva Comment Letter (November 30, 

2021) (‘‘Based on the survey we conducted, about 

1% of respondents indicated their plan to set up as 

high as 10–30 account administrators, while 4% 

indicated 20–150 users.’’). 

98See XBRL II Comment Letter (‘‘We believe that 

the limit of 500 authorized users per filer is 

sufficient.’’). 

99See Toppan Merrill Comment Letter 

(‘‘Additionally, EDGAR Next should allow an 

organization to add more than 500 authorized users, 

as needed.’’); DFIN Comment Letter (‘‘To 

accommodate larger entities, we suggest an increase 

to the authorized user limit from 500 to 1,500.’’). 

miss their annual confirmation 

deadlines an additional three months 

within which to perform their 

confirmation, during which time they 

will receive multiple notices, while 

maintaining good account hygiene by 

inactivating defunct accounts and 

safeguarding information regarding 

individuals listed in the dashboard of 

defunct filers. 

e. User Groups 

Largely as contemplated in the 

Proposing Release, the dashboard will 

provide functionality to allow an 

account administrator to group subsets 

of the filer’s users into user groups. The 

user group function will assist delegated 

entities to authorize certain of their 

users to make submissions on behalf of 

specific filers, as explained below. By 

employing user groups, the delegated 

administrator can add or remove the 

ability to make submissions for a certain 

filer to all users in the group at once and 

can give specific groups of users the 

ability to make submissions for certain 

filers, leading to efficiencies of time in 

managing users. 

One commenter stated that EDGAR 

should allow multiple users to be added 

to a user group simultaneously to ensure 

that user groups can be built quickly 

and efficiently.91 As requested by the 

commenter, the dashboard will be 

updated to permit filers to add multiple 

users to a user group simultaneously. In 

addition, optional APIs will be provided 

so that filers can view individuals in 

any role for a CIK, add individuals, 

remove individuals, and change roles 

for individuals; collectively, this should 

facilitate the ability of filers to manage 

user groups. 

One commenter stated that user group 

functionality would be improved by 

allowing wildcard searches to include 

first and last names.92 Accordingly, the 

dashboard will be enhanced to enable 

first and last name wildcard searches of 

individuals. 

2. Users 

Largely as contemplated in the 

Proposing Release, account 

administrators will be able to authorize 

individuals with individual account 

credentials as users to make 

submissions on EDGAR on behalf of the 

filer.93 Account administrators and 

Commission staff will be able to 

determine which users made which 

submissions; however, this information 

will not be made public on EDGAR. The 

dashboard will allow users to generate, 

view, and copy user API tokens, if using 

optional APIs that require presentation 

of a user API token; view relevant 

notifications (which will also be 

provided to users by email); and view 

basic information about the filer’s 

account, including the filer’s name, CIK, 

CCC, corporate and contact information, 

as well as contact information for 

account administrators. Users will not, 

however, be able to add or remove 

individuals from the dashboard other 

than themselves. Users also will not be 

able to generate a new CCC. Separately, 

users will be able to make COUPDAT 

submissions to update filer information 

such as name, address, and State of 

incorporation, as filers currently do. 

As part of the login and 

authentication process for the EDGAR 

filing websites, a user will be able to 

select the EDGAR account number (CIK) 

of the entity for which submissions are 

being made (‘‘login CIK’’). That CIK will 

be reflected in the first part of the 

unique identifier associated with each 

submission (the ‘‘accession number’’).94

Users will be able to change their login 

CIK at any time to any other account for 

which they are authorized. 

a. Becoming Authorized as a User 

An account administrator can ‘‘add’’ 

an individual through a dashboard 

function that will generate an invitation 

to the individual to be a user for the 

filer’s account. Prospective users will 

receive email invitations from EDGAR 

and, if the prospective user has a role 

for any EDGAR account, a notification 

of the invitation will appear on the 

prospective user’s dashboard. The 

individual must accept the invitation, 

through either the email or dashboard 

invitation, to become a user. As noted, 

the same process of invitation and 

acceptance both through email and the 

dashboard applies to all invitations. 

One commenter suggested the 

addition of functionality to allow filers 

to directly authorize their financial 

advisers (i.e., registered representatives 

of broker-dealers) to act as users.95

Although there are additional 

requirements related to the 

authorization of third parties as account 

administrators on Form ID, those 

requirements will not apply to users.96

Account administrators will be able to 

authorize any individual with Login.gov 

credentials as a user, therefore, for 

example, account administrators will be 

able to authorize financial advisers as 

users to make submissions on the filer’s 

behalf. 

b. Number of Users 

There will be no minimum number of 

users because account administrators 

will be able to make submissions on 

behalf of the filer. We are setting the 

maximum number of users per filer on 

the dashboard at 500, as proposed. 

The Proposing Release discussed a 

maximum of 500 users per filer, based 

in part on feedback received from 

commenters on the 2021 Request for 

Comment. One commenter that 

responded to the 2021 Request for 

Comment conducted a filer survey that 

indicated that 4% of the filers it 

surveyed would be interested in 

authorizing 20 or more users, up to a 

maximum of 150 users per filer.97 In 

response to the 500-user limit 

contemplated in the Proposing Release, 

one commenter agreed that a limit of 

500 users would be sufficient.98 In 

contrast, one commenter suggested that 

the limit should be increased but did 

not provide a specific number, while 

another suggested that the limit should 

be tripled to 1500 users per filer on the 

grounds that doing so would 

‘‘accommodate larger entities.’’ 99 We 

believe that a maximum of 500 users per 

filer on the dashboard should be 

sufficient to accommodate sophisticated 

filers making a large number of varied 


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100 In the future, if it seems that there is a need 

for additional users to be added, the limit on the 

number of users may be reevaluated. 

101See supra notes 97–98. 

102See generally section II.E. 

103See Toppan Merrill Comment Letter (‘‘[We] 

believe a technical administrator role is beneficial 

to help manage a filer’s use of APIs.’’); Workiva 

Comment Letter (‘‘[W]e agree with the option to 

have a technical administrator role for those who 

wish to utilize IT support to manage API tokens 

.... .’’). 

104See Block Transfer Comment Letter (‘‘We 

respectfully submit . . . an innovative approach 

. . . because(i) the role of technical administrator 

has material problems and (ii) other Federal 

agencies require machine-to-machine data 

submission from the private sector, most generally 

from financial services firms.’’). 

105See Block Transfer Comment Letter (‘‘We 

respectfully submit . . . an innovative approach 

. . . [that] envisages a unified, government-wide 

platform that ensures robust authentication and 

streamlined management of API interactions for 

various Federal services, including EDGAR. . . . 

For these reasons and more, we respectfully submit 

. . . that a brief Congressional consideration is in 

order to ponder the creation of a report as to the 

strengths and weaknesses a unified Login.gov 

machine-to-machine authentication system may 

bestow upon on our cybersecurity interests both 

domestically and abroad. . . .’’). 

106See generally section II.C.6. 

107As set forth in paragraph (d)(3) of Rule 10, 

filers who do not want their account administrators 

or users to generate user API tokens could 

alternatively allow their delegated entities to make 

submissions on their behalf through APIs, and 

individuals at the delegated entities would present 

their own user API tokens to make submissions. 

108See Workiva Comment Letter (‘‘[W]e believe 

that the administrator and the technical 

administrator can be the same person and would 

likely be most of the time.’’); XBRL II Comment 

Letter (‘‘We do not understand the difference 

between a technical administrator and an account 

administrator. The addition of a technical 

administrator role may further complicate the 

process. It could be useful if this role were optional 

and could be combined into the account 

administrator if the company chose to, for example 

if the account administrator could generate the filer 

token.’’). 

filings.100 Five hundred users is more 

than three times the high-end number 

cited in the commenter survey 

conducted in connection with the 2021 

Request for Comment, and was deemed 

to be sufficient by an industry 

membership organization.101 Moreover, 

filers will be able to more efficiently and 

rapidly make submissions through 

optional APIs, mitigating the need to 

have more than 500 users per filer.102

3. Technical Administrators 

Paragraph (d)(3) of Rule 10 as adopted 

and largely as proposed requires filers 

that opt to connect to the EDGAR APIs 

to authorize, through their account 

administrators, at least two technical 

administrators to manage the technical 

aspects of a filer’s connection to the 

APIs, unless the filer arranges to use its 

delegated entity’s API connections and 

the delegated entity is in compliance 

with the requirement to authorize at 

least two technical administrators. We 

anticipate that the role of technical 

administrator could be filled by 

someone with a primarily 

administrative background because the 

requirements of the role are to generate 

and provide filer API tokens and to 

manage the filer’s connections to APIs. 

We are not requiring that the technical 

administrator role be filled by software 

developers or other technically expert 

staff; rather, the technical administrator 

should have a basic understanding of 

API processes and be available to 

communicate with Commission staff 

and the filer’s developers or other 

technical experts expeditiously, in 

addition to generating and managing the 

filer API tokens. 

Commenters generally indicated 

support for adding a technical 

administrator role as beneficial to help 

manage a filer’s connection to APIs.103

One commenter suggested that it saw 

‘‘material problems’’ with the role of 

technical administrator but did not 

enumerate what those problems 

were.104 The commenter suggested 

Congressional consideration regarding 

creation of a ‘‘unified, government-wide 

platform that ensures robust 

authentication and streamlined 

management of API interaction for 

various Federal services, including 

EDGAR.’’ 105 We note that such an 

undertaking is outside the scope of this 

rulemaking. 

We are adopting paragraph (d)(3) of 

Rule 10 with a modification to permit a 

filer to use the API connections and filer 

API tokens of its delegated entity (as 

long as that delegated entity is in 

compliance with the requirement to 

authorize at least two technical 

administrators); and a filer that does so 

will not be required to authorize at least 

two technical administrators and 

generate a filer API token itself.106 The 

relevant individual at the filer 

interacting with the API, however, must 

present a valid user API token to the 

API if the relevant API requires 

presentation of a user API token, to 

allow identification of the individual 

taking action on EDGAR. To 

accommodate this change and to better 

reflect the technical connection of filers 

to the optional APIs, paragraph (d)(3) of 

Rule 10 will refer to filers that ‘‘connect 

to’’ APIs rather than filers that ‘‘use’’ 

APIs. This option is being offered for 

filers who would like their account 

administrators and users to be able to 

interact with the APIs directly, but who 

do not wish to undertake the expense to 

connect to the APIs and authorize 

technical administrators.107

a. Authority of Technical 

Administrators 

A technical administrator will issue 

and deactivate filer API tokens required 

to connect to the optional APIs. 

Technical administrators will also serve 

as points of contact for questions from 

Commission staff regarding the filer’s 

connections to the APIs and will receive 

relevant notifications on the dashboard 

and by email, such as reminders 

regarding upcoming expiration dates for 

filer API tokens. 

Two commenters suggested that the 

technical administrator and account 

administrator roles could be filled by 

the same person.108 As discussed in the 

Proposing Release, a filer will have the 

option of designating the same 

individual to serve as both its technical 

administrator and account 

administrator, but the filer may also 

choose to authorize different 

individuals to serve in these roles 

provided those individuals possess 

individual account credentials obtained 

in the manner specified in the EDGAR 

Filer Manual. 

b. Becoming a Technical Administrator 

To authorize an individual as a 

technical administrator, an account 

administrator will add the individual in 

that role on the dashboard, triggering an 

invitation to the individual. The 

prospective technical administrator will 

receive the invitation by email, and, if 

the individual already has a role for any 

EDGAR account, on the dashboard. The 

prospective technical administrator 

must accept either the dashboard or the 

email invitation to become authorized 

as a technical administrator. 

c. Number of Technical Administrators 

Paragraph (d)(3) of Rule 10 as 

proposed and adopted will require filers 

that choose to connect to an API to 

authorize, through its account 

administrators, at least two technical 

administrators. In a change to what was 

proposed, however, paragraph (d)(3) of 

Rule 10 will not impose a requirement 

to authorize at least two technical 

administrators if the filer arranges to use 

its delegated entity’s API connections 

and filer API tokens and the delegated 

entity is in compliance with the 

requirement to authorize at least two 

technical administrators. Further, while 

the Proposing Release indicated that 

filers would be able to authorize a 

maximum of 10 technical 

administrators, in response to requests 

from commenters, the maximum 

number of technical administrators will 

be increased to 20. 

One commenter generally supported 

the designation of at least two technical 


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109See Toppan Merrill Comment Letter (‘‘[A] 

minimum of two technical administrators should be 

required to manage a filer’s APIs. . . .’’). 

110See Workiva Comment Letter (‘‘[I]ndividuals 

or single-member firms should have the option to 

handle everything directly without involving an 

additional party. The requirement of at least two 

technical administrators would impose the need to 

involve a second person purely for the purpose of 

using software to file.’’); DFIN Comment Letter 

(‘‘We think the technical administrator minimum 

requirements should parallel the account 

administrator minimum requirements.’’). 

111See Block Transfer Comment Letter. 

112See Workiva Comment Letter (‘‘One solution 

would be to allow the registrant’s authorized user 

to use their token with the delegated filing 

software’s filer token.’’). 

113Alternatively, if filers wish to make 

submissions through APIs but do not wish their 

staff to be required to generate user API tokens, 

filers could arrange for their delegated entities to 

make submissions through APIs on their behalf. In 

this case, delegated entities would create the API 

connections, maintain at least two technical 

administrators, and generate filer API tokens, and 

the relevant delegated administrators and delegated 

users for these filers (at the delegated entities) 

would present their own user API tokens, if the 

APIs require presentation of a user API token. Of 

course, filers who wish to make submissions 

through APIs may also determine to create their 

own API connections to EDGAR, authorize at least 

two technical administrators, present their own filer 

API tokens, and have their account administrators 

and users generate and present their user API 

tokens, if the APIs require presentation of a user 

API token. 

114See Toppan Merrill Comment Letter (‘‘A 

minimum of two technical administrators should be 

required to manage a filer’s APIs, as proposed. We 

would prefer that the maximum number of 

technical administrators match the number of 

account administrators (20). This ensures that larger 

entities will not encounter any limitations.’’); 

Workiva Comment Letter (‘‘[T]he technical 

administrator and administrators can often be the 

same person. Thus, we believe the limits for 

administrators and technical administrators can be 

the same.’’). 

115See supra note 60. 

116An optional delegation API will be offered in 

addition to the delegation capabilities of the 

dashboard. 

117See, e.g., DFIN Comment Letter (‘‘Filers 

should be able to delegate to anyone they want to 

file on their behalf.’’); Toppan Merrill Comment 

Letter (‘‘We agree that an account administrator 

should be able to delegate filing authority to any 

EDGAR filer.’’). 

administrators for filers connecting to 

APIs.109 Two commenters generally 

supported the minimum of two 

technical administrators for companies, 

but asserted that only one technical 

administrator should be required for 

individuals and single-member 

companies, in order to parallel the 

minimum number of account 

administrators needed for those 

entities.110 One commenter stated that 

‘‘requiring two technical admins 

presents many material legal, efficiency 

and operational risks,’’ but did not 

specify the anticipated risks or how 

many technical administrators would be 

sufficient to address those anticipated 

risks.111 We believe that requiring a 

minimum of two technical 

administrators for filers that choose to 

connect to optional APIs will increase 

the likelihood that Commission staff can 

contact one of the filer’s technical 

administrators and reduce the chance of 

disruption of API connections. We 

believe that larger filers and filing 

agents using APIs should have sufficient 

staff to authorize two technical 

administrators. In addition, if 

individuals and single-member 

companies choose to connect to APIs, 

we anticipate that they will either 

employ filing agents, use their delegated 

entities’ API connections, or otherwise 

have available staff to comply with the 

paragraph (d)(3) requirement of Rule 10 

to authorize at least two technical 

administrators. 

As noted, as a departure from what 

was contemplated in the Proposing 

Release, a filer may use its delegated 

entity’s filer API tokens and API 

connections if the delegated entity is in 

compliance with the paragraph (d)(3) 

requirement of Rule 10 to authorize two 

technical administrators. The filer must 

delegate authority to file through the 

dashboard and coordinate with the 

relevant delegated entity to use the 

delegated entity’s API connections and 

filer API tokens, and the individual at 

the filer making the submission must 

present her own user API token to the 

API, if the relevant API requires 

presentation of a user API token. This 

change will obviate the need for filers to 

create their own API connections and 

authorize their own technical 

administrators should they want their 

account administrators and users to 

make submissions and interact with 

EDGAR through the optional APIs, and 

further responds to suggestions raised 

by a commenter.112 These filers may 

leverage the API connections and filer 

API tokens of filers’ delegated entities, 

and the individual at the filer need only 

supply her user API token to the API, 

if the relevant API requires presentation 

of a user API token.113

Because paragraph (d)(3) of Rule 10 as 

amended will require a filer to 

authorize, through its account 

administrators, at least two technical 

administrators to connect to the 

optional APIs, the dashboard will not 

allow a technical administrator to be 

removed from a filer’s account when 

only two technical administrators are 

authorized on the account. An account 

administrator will first need to add 

another technical administrator on the 

dashboard. 

In a change from the contemplated 

maximum of 10 technical administrators 

per filer, there will be a maximum of 20 

technical administrators per filer. 

Several commenters suggested that this 

limit be increased to parallel the limit 

for the maximum number of account 

administrators.114 Having the same 

maximum limit for account 

administrators and technical 

administrators will facilitate the ability 

of filers to authorize the same 

individuals in those roles. 

C. Delegated Entities 

Largely as contemplated in the 

Proposing Release, a filer will be able to 

delegate authority to file on its behalf to 

any other EDGAR account, such as a 

filing agent, which will become a 

delegated entity for the filer. As 

discussed above, the CCC will appear on 

the dashboard of individuals authorized 

to make submissions for the filer, 

including delegated administrators and 

delegated users.115

1. Delegating Authority To File 

A filer’s account administrator may 

delegate authority to file to another 

EDGAR account through a function on 

the dashboard, as discussed in the 

Proposing Release.116 After the account 

administrator selects the EDGAR 

account to which the filer seeks to 

delegate authority to file, EDGAR will 

send both email and dashboard 

invitations to the account administrators 

for that account. One account 

administrator for the prospective 

delegated entity must accept either the 

email or the dashboard invitation for the 

delegation to become effective. If the 

filer’s account administrators wish to 

terminate the delegation, they can do so 

on the dashboard. Removal of 

delegation will not require acceptance 

by the delegated entity. An account 

administrator will be able to delegate 

authority to file to an unlimited number 

of EDGAR accounts, allowing filers to 

delegate to multiple filing agents, for 

example, should they so choose. 

Similarly, an EDGAR account can 

accept an unlimited number of 

delegations from filers. 

In response to commenter 

suggestions, the dashboard will be 

enhanced to: (1) provide bulk delegation 

functionality to allow filers to delegate 

to multiple EDGAR accounts more 

easily; (2) enable prospective delegated 

entities to send delegation requests to 

filers; and (3) allow EDGAR accounts to 

automatically accept delegations and 

become delegated entities if they 

choose. 

Commenters generally supported the 

ability to delegate,117 although various 

commenters raised concerns about 

certain situations or recommended 


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118See, e.g., Comment Letter of Wanda Welch 

(November 13, 2023) (‘‘Welch Comment Letter’’) 

(‘‘We would like the ability to delegate to more than 

one CIK at a time and receipt of one email invite.’’); 

XBRL II Comment Letter (‘‘[We] recommend that a 

bulk delegation function be made available to assist 

filers that have multiple CIKs, and that this 

capability be allowed using a single invitation 

request (rather than multiple invitations for 

multiple CIKs.’’); DFIN Comment Letter (‘‘We think 

that a bulk delegation function would be beneficial 

for filers that have multiple CIKs. Also, the bulk 

delegation should produce one invitation request. 

The recipient would then only need to accept one 

invitation as opposed to several invitations.’’); ICI 

Comment Letter (‘‘There should be consideration 

for bulk delegation for a group of CIKs.’’). 

119See, e.g., SIFMA Comment Letter (‘‘We 

recommend that the system permit filing agents 

. . . to affirmatively request delegated authority (on 

an individual or bulk basis) from a given filer or 

filers.’’); Workiva Comment Letter (‘‘[We] 

recommend adding the capability for an entity to 

request delegation.’’); XBRL II Comment Letter 

(‘‘Vendors should be able to proactively request 

delegation from the registrant and receive 

confirmation [of delegation] on the site.’’). 

120See Workiva Comment Letter (‘‘[We] also 

suggest adding an option to allow filing agent-type 

CIKs to auto-accept delegations.’’); XBRL II 

Comment Letter (asserting that filing agents/ 

vendors should be able to request delegation, which 

could ‘‘be automatically approved by the 

registrant.’’). 

121See Block Transfer Comment Letter (‘‘There is 

real risk that delegates, armed with expansive filing 

capabilities, might submit false or misleading 

information, either inadvertently or maliciously.’’). 

122See, e.g., Welch Comment Letter (‘‘Does the 

Subject Company and the Co-registrants need to be 

delegated? ’’); DFIN Comment Letter (‘‘[F]ilers 

would face difficulties in delegating co-registrants. 

Especially when it relates to merger acquisitions 

that may include hundreds of co-registrants.’’). 

123See, e.g., Workiva Comment Letter (‘‘Only the 

primary registrant’s set of valid credentials should 

be required to file for all co-registrants, and 

delegation or a function to designate as ‘coregistrant’ is not necessary. Adding designation 

requirements significantly increases the risk for the 

overall filing submission.’’); XBRL II Comment 

Letter (‘‘We encourage the Commission to continue 

the existing beta implementation [for coregistrants], which only forces the Filer and User 

Token requirements for the primary registrant, into 

the final rule/implementation phase.’’). 

124See infra section II.E. 

125The ‘‘Retrieve/Edit Data’’ section of the 

EDGAR Filing website currently allows filers to 

perform certain administrative actions. Among 

other things, filers may view/edit their account 

information (such as the filer’s name, contact 

information, and corporate information like State of 

incorporation and fiscal year-end), view the filer’s 

current account balances and request the return of 

unused funds, and change the filer’s password or 

CCC. As part of the transition to EDGAR Next, some 

of this functionality will be shifted to the 

dashboard, such as the filer’s EDGAR POC. See 

infra note [125] and accompanying text. 

126As discussed further below in section II.C, the 

dashboard will generally be used to manage a filer’s 

EDGAR account, including management of 

individuals authorized to act as account 

administrators, users, and technical administrators; 

management of entities authorized to act as 

delegated entities; and management of filer and user 

API tokens. Delegated entities will not need to 

access the filer’s dashboard in order to make filings 

on the filer’s behalf, since filings will be made 

directly on the EDGAR filing websites or through 

the optional APIs, as opposed to through the filer’s 

dashboard. 

certain changes as discussed further 

herein. Multiple commenters requested 

that bulk delegation be permitted, so 

that filers could delegate to multiple 

EDGAR accounts simultaneously via a 

single invitation.118 After considering 

these comments, bulk delegation 

functionality will be added to the 

dashboard to allow filers to delegate to 

multiple EDGAR accounts more easily. 

For recordkeeping and administrative 

purposes, delegated administrators will 

receive separate invitations for each 

delegation, but they will be able to 

accept multiple invitations in bulk, 

which should address commenters’ 

concerns about minimizing burdens on 

delegated administrators who receive 

bulk delegations. 

Multiple commenters also asked that 

prospective delegated entities be able to 

request delegation.119 This process 

would enable filing agents, for example, 

to assist their client filers in delegating 

to the correct EDGAR accounts. In 

response to these comments, the 

dashboard will be enhanced to enable 

prospective delegated entities to send 

delegation requests to filers. The 

delegation requests will prompt filers’ 

account administrators to send 

delegation invitations to the delegated 

entities, and filers’ account 

administrators can determine whether 

they wish to send such delegation 

invitations. If the filers’ account 

administrators send the delegation 

invitations, the delegated entities’ 

account administrators must accept the 

invitations for the delegation to be 

effective. 

Separately, several commenters 

requested that prospective delegated 

entities be able to automatically accept 

delegation invitations to lessen the 

burden on delegated entities’ account 

administrators to manually accept each 

invitation.120 The dashboard will be 

enhanced accordingly to allow 

prospective delegated entities to opt to 

automatically accept delegation 

invitations. 

One commenter was critical of the 

proposal’s delegation of authority 

capabilities, warning that broad 

permissions granted to delegated 

entities to make submissions for the filer 

represent a significant risk regarding the 

accuracy and authenticity of filings.121

We do not believe a delegated entity 

with permissions to make submissions 

for the filer will pose a significant risk 

because such risk is mitigated through 

the authorization requirements and 

verification. For example, delegated 

entities must be authorized and 

confirmed by a filer’s account 

administrator on the dashboard, 

ensuring that only authorized and 

trusted entities are able to make 

submissions for the filer. Additionally, 

a delegated entity must have an EDGAR 

account and will be subject to the same 

requirements applicable to all filers. For 

the delegation to become effective, an 

account administrator of the delegated 

entity must accept the invitation, which 

means the account administrator at the 

delegated entity must first log into 

EDGAR using her individual account 

credentials and perform multifactor 

authentication. 

Commenters also raised concerns 

regarding burdens potentially associated 

with delegating authority to make 

submissions to co-registrants and asked 

for clarity regarding how such 

delegations would work.122 Commenters 

further urged the Commission not to 

require that co-registrants be added to 

an EDGAR account as a user, account 

administrator, delegated user, or 

delegated administrator to make 

submissions, so long as the individual 

making the submission had the correct 

role-based permissions for the primary 

registrant and had provided the correct 

CCCs for the co-registrants, as currently 

required.123 We acknowledge that 

requiring separate dashboard 

permissions for each co-registrant to 

make submissions could potentially be 

confusing. We also recognize concerns 

that commenters separately raised about 

the need for additional optional APIs, 

including APIs to verify filing 

credentials, view filer account 

information, and replicate dashboard 

functionality that would assist filers if 

co-registrants were required to have 

dashboard permissions to make 

submissions.124 EDGAR will not require 

role-based permissions for co-registrants 

at this time, and the addition of coregistrants to a filing will continue to be 

performed the same way it is currently 

performed (i.e., simply by listing the 

CIK and CCC of each co-registrant). 

2. Separation of Authority of Filer and 

Delegated Entity 

A filer’s account administrator will 

not be able to access its delegated 

entity’s dashboard or account or add or 

remove delegated users at the delegated 

entity, as discussed in the proposal. 

While delegated administrators and 

delegated users will be able to make 

EDGAR submissions and access the 

‘‘Retrieve/Edit Data’’ section of the 

EDGAR Filing website on the filer’s 

behalf,125 delegated administrators and 

delegated users similarly will not be 

able to access the filer’s dashboard 126 or 


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127See DFIN Comment Letter (‘‘Delegated 

administrators and delegated users should have the 

ability to submit COUPDAT (company update 

submissions) and SCUPDAT (series & class 

updates).’’). 

128For example, Filer A could delegate authority 

to file on its behalf to Filer B. Separately, Filer B 

could delegate authority to file on its behalf to Filer 

C. In this scenario, however, Filer B could not 

delegate to Filer C the authority to file on behalf of 

Filer A, and Filer C could not file on behalf of Filer 

A. 

129We are adopting amendments to Rule 11 of 

Regulation S–T to define a ‘‘filing agent’’ as any 

person or entity engaged in the business of making 

submissions on EDGAR on behalf of filers. This 

definition includes law firms, financial services 

companies, broker dealers when making 

submissions on behalf of individuals filing 

pursuant to section 16 of the Exchange Act, and 

other entities engaged in the business of submitting 

EDGAR filings on behalf of their clients. See the 

discussion of amendments to Rule 11 in section 

II.F.2. 

130See XBRL II Comment Letter (‘‘Yes, the ability 

to delegate authority would help infrequent filers 

such as Section 16 filers.’’); Workiva Comment 

Letter (responding to the Commission’s request for 

comment regarding section 16 filers by stating: ‘‘We 

believe the proposed framework is adequate to 

support filing responsibilities.’’). 

131See XBRL II Comment Letter (‘‘[W]e do not 

believe the rule proposal adequately addresses the 

needs of Section 16 filers and single individual 

filers [who] will perform their own code 

management. For these filers, the rule does not 

specifically address how they can manage this. 

Many sit on boards of multiple companies, some as 

many as 20, and will need to set up or designate 

each individual as an account administrator. The 

Commission needs to address how there can be an 

easier method to delegate permission for someone 

to file on their behalf.’’). 

132See supra note 107 and accompanying and 

following text; see also Toppan Merrill Comment 

Letter (‘‘Allow bulk delegation for a group of CIKs. 

This would be useful for an Administrator of an 

Issuer and all of their Section 16 filer CIKs to 

delegate to Filing Agents as well as affiliated 

CIKs.’’). 

take dashboard actions on behalf of the 

filer. 

Separately, as one commenter 

requested, the dashboard will be 

modified to allow delegated 

administrators and delegated users to 

make both COUPDAT and series and 

class update (‘‘SCUPDAT’’) 

submissions. The Proposing Release 

contemplated that delegated 

administrators and delegated users 

would be able to submit SCUPDAT 

submissions on the filer’s behalf to 

update series and class information 

(such as a new share class) but would 

not be able to make COUPDAT 

submissions to update the filer’s 

company information (such as a new 

business address). One commenter 

asserted that delegated administrators 

and delegated users should be able to 

submit both COUPDATs and 

SCUPDATs on behalf of the filer.127

Because allowing delegated 

administrators and delegated users to 

make both COUPDAT and SCUPDAT 

submissions provides consistency and 

reduces burdens associated with these 

updates, to the extent that such updates 

could then be delegated by the filer, this 

capability will be implemented in 

EDGAR. The filer’s account 

administrators would receive notice of 

COUPDAT and SCUPDAT submissions 

on the dashboard and could take 

appropriate action should any 

unauthorized activity occur. 

Delegated entities will not be able to 

further delegate authority to file to other 

entities on behalf of filers that delegate 

authority to them.128

3. Delegated Entities 

Because a delegated entity must have 

an EDGAR account, it must comply with 

the same requirements applicable to all 

filers. A delegated entity will therefore 

maintain its own EDGAR account with 

its own account administrators, users, 

and technical administrators. A 

delegated entity can be any EDGAR 

account, including but not limited to 

filing agents,129 issuers making 

submissions on behalf of individuals 

filing pursuant to section 16 of the 

Exchange Act,a nd parent companies of 

large groups of related filers. On the 

dashboard, a delegated entity will be 

able to receive delegated authority to 

file for an unlimited number of filers. 

Several commenters provided 

comments on delegation specifically 

related to individuals with filing 

obligations pursuant to section 16 of the 

Exchange Act. Commenters indicated 

that the delegation framework 

contemplated by the Proposing Release 

would help section 16 filers comply 

with their filing obligations.130

Individuals with section 16 filing 

obligations will be able to delegate 

authority to make submissions to filing 

agents or any other representative with 

an EDGAR account on the dashboard. 

This process will allow those 

individuals to obtain assistance with 

their filings, while permitting each 

filing to be associated with a specific 

individual at the delegated entity. One 

commenter asserted that section 16 

filers would face compliance burdens, 

however, that would not be adequately 

addressed by the proposal.131 The 

commenter stated that section 16 filers 

can sit on the boards of multiple 

companies and concluded that section 

16 filers need an easier method to 

delegate permissions. As discussed 

above and as separately requested by 

commenters, the dashboard will include 

bulk delegation functionality, which 

should assist filers with multiple filing 

agents or other representatives with 

EDGAR accounts, including section 16 

filers delegating authority to make 

submissions to related issuers.132 The 

staff will provide detailed information 

about bulk delegation and other account 

management topics to section 16 filers 

to prevent confusion. Moreover, section 

16 filers may choose to execute 

notarized powers of attorney to 

authorize relevant individuals at their 

filing agents, related issuers, or other 

representative entities as account 

administrators, thereby avoiding the 

need to obtain individual account 

credentials, log into the dashboard, 

make filings or delegate authority on the 

dashboard. 

If a filer authorizes a delegated entity 

to file on its behalf, one of the delegated 

entity’s account administrators must 

accept either the dashboard or the email 

invitation for the delegation to be 

effective; further, upon acceptance, all 

the delegated entity’s account 

administrators will automatically 

become delegated administrators for the 

filer. All delegated administrators for 

the filer will have co-equal authority 

with regard to that filer. If the delegated 

entity adds or removes one of the 

account administrators for its own 

EDGAR account, then that individual 

will also be added or removed as a 

delegated administrator for the filer. 

These relationships are illustrated in 

diagram 3 below. 


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133For this reason, delegated administrators 

could not be authorized as delegated users 

regarding the delegating filer, because doing so 

would be redundant. 

134See Workiva Comment Letter (‘‘[D]elegated 

admins should be able to remove a delegated user 

from all delegations without having to edit each 

delegation one by one as the person may need to 

remain on the Dashboard for a role other than the 

delegated role.’’). 

135See Workiva Comment Letter (‘‘[D]elegated 

users should have the ability to remove themselves 

from all delegations without editing one by one.’’). 

136See text following note 118 (discussing the 

dashboard’s bulk delegation functionality). 

4. Delegated Users 

As described in the Proposing 

Release, if a delegated entity accepts a 

delegation from a filer, the delegated 

administrators can authorize specific 

users at the delegated entity to become 

delegated users with respect to that filer. 

As discussed below, delegated 

administrators will be able to authorize 

delegated users in accordance with the 

process outlined in the Proposing 

Release. In addition to what was 

discussed in the Proposing Release and 

taking account of a commenter’s 

suggestion, the dashboard will be 

updated to generally enable bulk actions 

in various contexts, including 

delegation. 

Delegated users will not count as part 

of the 500-user limit on the dashboard 

for the delegating filer. If delegated 

administrators want all their users to 

become delegated users with respect to 

a filer, a delegated administrator can 

check a box on the dashboard to 

automatically authorize all users at the 

delegated entity as delegated users for 

the filer. Alternately, delegated 

administrators will be able to authorize 

a subset of the delegated entity’s users 

as delegated users; authorize all of the 

delegated entity’s users as delegated 

users for the filer; or not authorize any 

delegated users (because the delegated 

administrators will be able to file on 

behalf of the filer).133 After the 

delegated user accepts the initial 

invitation from the delegated 

administrator, the user will receive 

notifications regarding further changes 

to its role (including changes to filers for 

which it will be a delegated user, and 

changes to the user groups it will be 

affiliated with), but the user will not 

need to accept those notifications or 

take any further action for the changes 

to be effective. 

One commenter stated that delegated 

administrators should be able to remove 

a delegated user from all delegations via 

a single bulk action without having to 

manually edit each delegation.134 The 

commenter further asserted that 

delegated users should be able to 

remove themselves from all delegations 

without editing each delegation.135 In 

these circumstances, we believe that it 

is more likely that a delegated 

administrator would remove a delegated 

user, or the delegated user would 

remove herself, as a user for the 

delegated filer, and thus the dashboard 

will not specifically provide these 

requested features. The dashboard will 

be enhanced, however, to generally 

enable bulk actions in various contexts, 

including with respect to delegation.136

In addition, optional APIs will be 

offered to allow filers to add and remove 

individuals’ authorizations rapidly and 

easily. These accommodations should 

largely address commenters’ concerns; 

in addition, further technical 

enhancements to the dashboard will 

continue to be considered. 

Delegated users will be able to submit 

filings on behalf of the filer on the 

EDGAR filing websites or through the 

optional submission API, as discussed 

below. 

5. User Group Functionality at 

Delegated Entities 

Delegated entities, through their 

delegated administrators, will be able to 

employ user groups to assign certain 

users to different filers for which they 

possess delegated authority to file, as 

described in the Proposing Release. An 

example is provided in diagram 4 

below. 


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137See supra note 92 and accompanying and 

following text. 

138See, e.g., Toppan Merrill Comment Letter (‘‘It 

would be beneficial to allow the dashboard to be 

open 24 hours a day, Monday through Friday.’’); 

Block Transfer Comment Letter (‘‘We respectfully 

Continued 

• In diagram 4, the account 

administrators for Filer A and Filer B 

delegated to Filer C. As a result, Filer 

C’s account administrators became 

delegated administrators for Filers A 

and B. In this example, Filer C might be 

a filing agent to which Filer A or Filer 

B gave authority to make filings on its 

behalf, and Filer A and Filer B might be 

public companies or investment 

companies. 

• A delegated administrator at Filer C 

created User Group 1 containing Filer 

C’s Users 1, 2, and 3. The delegated 

administrator assigned authority to file 

for Filer A to User Group 1. Users 1, 2, 

and 3 are thus delegated users for Filer 

A because they are members of User 

Group 1. If additional users from Filer 

C were added to User Group 1, those 

additional users would also become 

delegated users for Filer A. 

• The delegated administrator at Filer 

C also created User Group 2 containing 

Filer C’s User 3. The delegated 

administrator assigned authority to file 

for Filer B to User Group 2. User 3 is 

a delegated user for Filer B. 

• By employing the user group 

function, the delegated administrator at 

Filer C restricted delegated filing 

permissions for Filer A to Filer C Users 

1, 2, and 3 only (via User Group 1) and 

delegated filing permissions for Filer B 

to Filer C User 3 only (via User Group 

2). Filer C User 4 has not been 

authorized as a delegated user for any 

filers. 

• In diagram 4, each user group has 

only been assigned authority to file for 

a single filer, but user groups could be 

assigned authority to file for multiple 

filers. 

Delegated administrators will also be 

able to authorize a default user group of 

individuals who will be automatically 

assigned as delegated users for all future 

delegations. The ability to have a default 

user group will provide an efficient way 

for delegated administrators to authorize 

groups of their users as delegated users 

for any filer. 

Users will receive notifications when 

added to or removed from a user group, 

and when the user group to which they 

belonged becomes authorized to make 

submissions for a filer, or when that 

authorization is removed. As noted, 

users will not need to accept or 

otherwise take any action on these 

notifications. 

As discussed above, in response to 

comments received, the dashboard will 

be enhanced to allow wildcard searches 

including first and last names, which 

should make it easier for filers to 

construct user groups and to generally 

manage individuals on the 

dashboard.137

6. Technical Administrators at 

Delegated Entities 

If the delegated entity chooses to 

connect to APIs, the delegated entity 

will be required to authorize its own 

technical administrators, as discussed in 

the Proposing Release, and required by 

paragraph (d)(3) of Rule 10 as adopted. 

The delegated entity’s technical 

administrators will be responsible for 

managing the API connections and the 

filer API tokens for the delegated entity. 

The delegated entity may make 

submissions for any filers that delegate 

authority to it using the delegated 

entity’s API connections and filer API 

tokens, and the individual at the 

delegated entity making submissions for 

the filer would present his user API 

token generated on the dashboard, if the 

relevant API requires presentation of a 

user API token. 

In addition, as discussed above, in a 

change from what was contemplated in 

the Proposing Release, paragraph (d)(3) 

of Rule 10 as adopted now specifies that 

a filer may use its delegated entity’s API 

connections and filer API tokens so long 

as the delegated entity complies with 

the requirement to maintain at least two 

technical administrators. The delegated 

entity’s technical administrators may 

share the delegated entity’s filer API 

tokens with its filers, as discussed 

further below. The delegated entity’s 

technical administrators will not need 

to generate different filer API tokens for 

different delegating filers that use the 

delegated entity’s API connections. The 

individual at the filer using the 

delegated entity’s API connections and 

filer API tokens must present her own 

user API token to the APIs, if the 

particular APIs require presentation of a 

user API token. 

D. Hours of Operation of the Dashboard 

As contemplated in the Proposing 

Release, the dashboard will be available 

during EDGAR operating hours, 6 a.m. 

to 10 p.m. Eastern Time each day except 

Saturdays, Sundays, and Federal 

holidays. Optional APIs that provide 

much of the same functionality as the 

dashboard will also be available during 

those hours because the APIs rely on 

dashboard availability. 

Several commenters requested 

increased dashboard operating hours, 

including requests that the dashboard be 

available during weekends and/or 24 

hours a day.138 While we acknowledge 


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believe the Commission should not limit EDGAR 

Next operations to the DC workweek. . . . [W]e 

believe a 24/7 EDGAR would revolutionize 

international capital markets by providing a 

standard for all issuers.’’). 

139Regulation S–T provides that filings ‘‘may be 

submitted to the Commission each day, except 

Saturdays, Sundays, and Federal holidays, from 6 

a.m. to 10 p.m., Eastern Standard Time or Eastern 

Daylight Saving Time, whichever is currently in 

effect.’’ 17 CFR 232.12(c). 

140See, e.g., Comment Letter of Andrew Danneffel 

(November 20, 2023) (‘‘Danneffel II Comment 

Letter’’) (‘‘The introduction of APIs to interact with 

EDGAR is very much welcome.’’); Toppan Merrill 

Comment Letter (‘‘The proposed APIs accomplish 

the objectives of secure, efficient, and automated 

machine-to-machine communication.’’); Comment 

Letter of Chris V. (Nov 21, 2023) (‘‘Chris V. 

Comment Letter’’) (‘‘For this proposal, I believe 

specifically the API access outlined in Rule 10(d)(3) 

is the most crucial item which should be added to 

the regulations.’’). 

141See, e.g., Workiva Comment Letter (‘‘All 

functionality provided by the EDGAR Dashboard 

should be available via APIs. . . . The 

administration burden and ongoing maintenance 

costs [of manually using the dashboard] will be 

significant and could ultimately impact the cost 

burden on the filers’’); XBRL II Comment Letter (‘‘A 

complete set of Filer Management APIs must be 

made available for effective management by filing 

agents and other entities that support large numbers 

of registrants. . . . This scale is not manageable 

using the Filer Management dashboard and would 

result in an overwhelming amount of email and 

incur a significant support burden and associated 

costs.’’); Chris V. Comment Letter (‘‘My suggestion 

for improving the proposal is to provide the API on 

a wider scale.’’). 

142See, e.g., ICI Comment Letter (‘‘EDGAR Next 

should provide a mechanism to provide for filers 

who have a multi-filer structure, such as Funds.’’); 

Toppan Merrill Comment Letter (‘‘EDGAR Next 

should provide a mechanism to affiliate and 

manage filers who have a multi-filer structure.’’). 

143The APIs will be available concurrently with 

EDGAR Filer Management dashboard availability— 

during EDGAR business hours, from 6 a.m. to 10 

p.m. Eastern Time, each day except Saturdays, 

Sundays, and Federal holidays. See section II.D. 

144This requirement is included in the EDGAR 

Filer Manual, as amended. See amended EDGAR 

Filer Manual, Volume I. We note that specific 

required inputs vary by API. For example, the 

EDGAR operational status API will not require user 

API tokens, as discussed further below. 

commenters’ concerns, the dashboard 

will be available during current EDGAR 

operating hours, the time period during 

which EDGAR filings can be 

submitted,139 which is 16 hours per 

business day. We believe this 

availability should generally be 

sufficient for filers’ needs, as it has been 

for EDGAR filing availability to date. 

Further, optional APIs providing much 

of the functionality on the dashboard 

will allow filers to rapidly make 

submissions and otherwise transmit and 

receive information from EDGAR, 

significantly increasing filers’ efficiency 

during EDGAR operating hours. In 

addition, filers that build internal 

systems to connect to the optional APIs 

could potentially include features such 

as scheduling filings for submission, as 

filers currently do, reducing the need for 

the dashboard to be offered 24 hours a 

day or during weekends and holidays. 

E. Optional Application Programming 

Interfaces 

Commenters broadly supported the 

addition of optional APIs to EDGAR, 

including those listed in the Proposing 

Release.140 EDGAR will therefore offer 

the optional APIs detailed below to 

provide filers with secure, efficient and 

automated methods of interacting with 

EDGAR. These optional APIs will be 

available to enrolled filers upon the 

effective date of the rule and form 

changes on March 24, 2025. The 

optional APIs include those discussed 

in the Proposing Release—a submission 

API to allow filers to make both live and 

test submissions on EDGAR 

(‘‘submission API’’); a submission status 

API to allow filers to check the status of 

an EDGAR submission (‘‘submission 

status API’’); and an operational status 

API to allow filers to check EDGAR 

operational status (‘‘EDGAR operational 

status API’’)—as well as 12 additional 

optional APIs requested by commenters, 

detailed below. 

Commenters recommended that 

optional APIs mirroring the 

functionality in the dashboard be added 

to those discussed in the Proposing 

Release to reduce the burden associated 

with manual dashboard tasks.141 We 

will offer the majority of APIs that 

commenters requested, which should 

largely address commenters’ concerns 

regarding account administrators’ 

manual management of numerous 

individuals and accounts on the 

dashboard, as well as commenters’ 

request for enhanced EDGAR 

automation. For example, APIs will 

assist individuals who are account 

administrators for multiple EDGAR 

accounts, such as investment company 

fund families or asset-backed securities 

issuers with potentially hundreds of 

affiliated EDGAR accounts.142 We 

previously indicated that more APIs 

would be added if feasible, and the 

additional APIs requested by 

commenters will be made available to 

enrolled filers when the EDGAR Filer 

Management dashboard goes live on 

March 24, 2025. In addition, filers 

whose application on amended Form ID 

is granted on or after March 24, 2025, 

will be able to connect to the optional 

APIs. Collectively, the optional APIs 

will provide in machine-to-machine 

connections the majority of functions on 

the dashboard for those filers that 

choose to manage their EDGAR accounts 

in a more automated manner.143

Additional APIs may be made available 

in the future as feasible. Connection to 

APIs is optional. 

If filers choose to connect to APIs, 

filers must comply with the requirement 

of paragraph (d)(3) of Rule 10, as 

adopted, to authorize, through their 

account administrators, at least two 

technical administrators, unless the filer 

uses the filer API tokens and API 

connections of its delegated entity (so 

long as that entity is in compliance with 

the requirement to maintain at least two 

technical administrators pursuant to 

paragraph (d)(3) of Rule 10), as 

discussed further herein. Additionally, 

filers that choose to connect to the APIs 

must comply with the requirements of 

the EDGAR Filer Manual as amended to 

present filer API tokens and user API 

tokens to EDGAR generated on the 

dashboard on a periodic basis, unless 

filers use the filer API tokens and API 

connections of their delegated entity 

(and the individual at the filer presents 

her user API token, if required by that 

API). Filers, including delegated 

entities, that maintain at least two 

technical administrators and connect to 

APIs must present a filer API token and 

the individual at the filer must present 

a user API token to the APIs (if the 

relevant API requires a user API token). 

If a filer chooses to use the filer API 

token and API connections of its 

delegated entity, that filer’s individual 

account administrator or user must still 

present to the API a user API token the 

individual generates on the dashboard 

(if the relevant API requires a user API 

token).144

The API tokens represent a security 

requirement that eliminates the need for 

manually entering individual account 

credentials and performing multifactor 

authentication each time a submission 

is made. Instead, multifactor 

authentication and individual 

identification occurs when the technical 

administrator logs into the dashboard to 

generate the filer API token annually 

and when the relevant account 

administrator or user logs into the 

dashboard to generate a user API token 

every 30 days, in accord with the time 

durations of the tokens specified in the 

EDGAR Filer Manual as amended. 

Filers who choose to connect to 

optional APIs will need to create certain 

software to make technical connections 

to the APIs, as they would any other 

API. Commission staff are providing 

filers with open-source code for a 

sample filing application that will 

facilitate filers’ connections to the three 

APIs noted in the Proposing Release in 

the EDGAR API Development Toolkit 

(‘‘API Toolkit’’), available on SEC.gov. 

The sample filing application will 


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145The sample filing application code is a starting 

point for smaller filers that may not already have 

a filing application and want to enter the API space. 

This sample code can serve as a troubleshooting 

guide/reference material for all developers because 

it uses specific technologies (e.g., PostgreSQL, 

NodeJS, Angular) that are well documented, 

standard, and can be understood by a mid-level 

programmer. 

146Currently, EDGAR accepts approximately 525 

submission types, of which approximately 500 

(95%) permit filer construction. 

147Filers who do not wish to use the API to make 

filer-constructed submissions, and filers making 

other types of submissions, could continue to file 

through the web-based EDGAR filing websites. 

Whether submissions were made through the API 

or the EDGAR filing websites, filers will specify the 

CIK for which they are making submissions. That 

CIK number will be reflected in the accession 

number associated with those submissions. Filers 

could change the login CIK reflected in the 

accession number at any time to any other CIK for 

which the filer is authorized to file on EDGAR. For 

example, a filing agent could choose to submit 

filings for a client filer using its own login CIK, or 

by using its client filer’s login CIK. 

148See Block Transfer Comment Letter (‘‘We 

respectfully present to the Commission that there 

should be submission endpoints specific to major 

forms offered to filers. Specific routes for each filing 

enable the Commission to check for route-specific 

endpoint authorization. That way, an issuer that 

authorizes another filer to submit automated insider 

transaction reports does not have to worry about the 

agent submitting a Form 10–K.’’). 

149 Generally, filings are first accepted and then 

subsequently disseminated. Certain filings, 

however, remain nonpublic and are never 

disseminated. Therefore, those filings never 

progress from accepted to disseminated status. 

150See Workiva Comment Letter (‘‘Missing 

information includes, but is not limited to, 

warning/error labels (as shown on https://

www.sec.gov/edgar/messages), the number of 

documents processed, the received and filing dates, 

series/class information, Section 16 reporting 

owner/issuer details, Subject Company, file 

number(s), and Item Submission accession number 

and type information for combined filings. The 

current Submission Notification HTML document 

contains this information and the API should be 

modified to include this document . . . .’’). 

151See, e.g., Workiva Comment Letter (‘‘We 

suggest adding an API which would return specific, 

comprehensive information about the status of all 

credentials involved in an API-based filing.’’); 

Danneffel II Comment Letter (‘‘I’d like to suggest an 

additional API be added that tests the validity of a 

user/filer token combination . . . ., The proposed 

API would check:—If the user token is valid (exists 

and is not expired)—If the filer token is valid (exists 

and is not expired)—If the user token is authorized 

to file using the filer token . . . .’’). 

152See Workiva Comment Letter (‘‘This new API 

would be accessed prior to every filing submission, 

so it could be expected to be called thousands of 

times per day—although detecting authorization 

errors prior to submitting a filing would reduce the 

amount of invalid filing submissions and would 

reduce the load on both filing software and EDGAR 

systems.’’). 

provide technical details and a working 

code base that could be either copied 

into existing filing applications or used 

as a base for developing a new filing 

application.145 Commission staff are 

also offering filers a list of technical 

standards for the APIs, the expected 

inputs and outputs, and information 

regarding whether only a filer API token 

or both filer and user API tokens are 

required for particular APIs in the 

Overview of EDGAR Application 

Programming Interfaces (‘‘Overview of 

EDGAR APIs’’), available on SEC.gov. 

We anticipate that the API Toolkit and 

the Overview of EDGAR APIs will save 

filers time and effort in connecting to 

the optional APIs. 

1. APIs That Commission Staff Will 

Provide 

a. Submission API 

Consistent with the discussion in the 

Proposing Release, the submission API 

will give filers the option to submit test 

and live filer-constructed EDGAR 

submissions.146 This API should allow 

filers to rapidly and efficiently submit 

large numbers of filings in an automated 

manner, instead of requiring them to 

manually log into EDGAR to make 

filings one at a time.147 Successful 

connection to the submission API will 

transmit a filer-constructed submission 

to EDGAR, at which point the 

submission will be subject to routine 

EDGAR validation checks and 

processing. 

One commenter suggested the 

introduction of submission endpoints 

specific to major forms offered to 

filers.148 The commenter asserted this 

could be used to control filing 

permissions for specific forms so that, 

for example, a filer could delegate 

permissions for only certain specific 

form types. Although some filers may 

wish to engage in limited delegations of 

authority, there is no current plan to 

introduce that level of granularity to 

EDGAR. Under EDGAR Next, a filer’s 

account administrators will receive a 

notification when the delegated entity 

makes a submission for the filer, and if 

that submission is made without the 

filer’s authorization, the filer’s account 

administrators will be able to remove 

the delegated entity’s authority to make 

submissions on the filer’s behalf and 

take other corrective actions. Moreover, 

providing form-specific filing 

permissions could be logistically 

difficult to administer as EDGAR 

currently accepts 525 submission types. 

b. Submission Status API 

As discussed in the Proposing 

Release, a submission status API will 

allow filers to leverage their filing 

application to simultaneously check the 

status of multiple submissions in a 

batch process, instead of manually 

logging into EDGAR and individually 

checking the status of each submission. 

The submission status API will indicate 

whether each submission has been 

submitted and accepted, but not yet 

publicly disseminated; 149 submitted 

and accepted, and publicly 

disseminated; or submitted and 

suspended. 

One commenter requested that the 

submission status API be modified to 

provide additional information so that 

filers could more fully understand the 

exact status of their EDGAR 

submissions.150 As requested by the 

commenter, the submission status API 

will be enhanced to provide all 

information currently contained in 

EDGAR submission notifications. 

c. EDGAR Operational Status API 

As discussed in the Proposing 

Release, an EDGAR operational status 

API will allow filers to leverage their 

filing application to check the 

operational status of EDGAR at any 

given time. The EDGAR operational 

status API will indicate whether EDGAR 

is fully operational, unavailable (after 

business hours), or not fully operational 

in whatever regard at that point in time 

(for example, if EDGAR is not 

disseminating to SEC.gov). We did not 

receive any comments specifically 

regarding the EDGAR operational status 

API. 

In addition to the APIs discussed in 

the Proposing Release, the following 

APIs will be offered in response to 

commenter requests, as described 

below. 

d. Filing Credentials Verification API 

Several commenters requested the 

addition of an API to allow filers to 

confirm the validity of all credentials 

involved in an API-based filing.151 One 

commenter asserted that this API would 

be used thousands of times per day and 

would help detect authorization errors 

prior to submission, which would in 

turn reduce the amount of invalid filing 

submissions and reduce the load on 

both filing software and EDGAR 

systems.152 A ‘‘filing credentials 

verification API’’ will be added, as 

requested by commenters, which should 

assist filers in verifying the status of 

their credentials, allowing them to 

accurately schedule and submit filings. 

The API will indicate if the provided 

credentials have filing permissions with 

regarding the provided CIK, and if so, 

will also provide the upcoming account 

confirmation deadline and the 

expiration dates of the provided API 

tokens. 


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153See Workiva Comment Letter (‘‘All 

functionality provided by the EDGAR Dashboard 

should be available via APIs. While the Dashboard 

may be sufficient for individual registrants, it will 

be unworkable for many filing agents.’’); XBRL II 

Comment Letter (‘‘A complete set of Filer 

Management APIs must be made available for 

effective management by filing agents and other 

entities that support large numbers of 

registrants. . . . This scale is not manageable using 

the Filer Management dashboard and would result 

in an overwhelming amount of email and incur a 

significant support burden and associated cost.’’). 

154 In addition, APIs will be provided related to 

delegation and CCCs. 

155See supra note 141153. 

156See XBRL II Comment Letter (‘‘All 

functionality provided under the Retrieve/edit data 

section of the EDGAR site should have an 

equivalent API implementation. . . .’’); Toppan 

Merrill Comment Letter (‘‘Ideally, all functionality 

that is currently available within the ‘Retrieve/Edit’ 

data under a CIK within EDGAR will be available 

through an API in EDGAR Next.’’). 

157Filing fee information will remain in the 

‘‘Retrieve/Edit Data’’ section of the EDGAR Filing 

website; it will not be accessible on the dashboard. 

158See, e.g., Workiva Comment Letter (‘‘[W]e 

suggest automatically enrolling the current POC as 

a super administrator by default. . . . We highly 

recommend that the initial transition should 

include preloaded delegations based on filing 

history, with the option of automatic acceptance by 

filing agents. . . .’’); XBRL II Comment Letter (‘‘We 

recommend that the CSV limit be increased to 500, 

from the proposed limit of 100.’’). 

159Workiva Comment Letter (‘‘[T]he proposed 

delegation scenario is not well suited for automated 

filing solutions, since while the filing software can 

e. APIs To View Individuals, Add 

Individuals, Remove Individuals, and 

Change Roles 

Several commenters requested the 

addition of optional APIs to replicate 

dashboard functionality to allow filing 

agents and other entities that support 

large numbers of registrants to more 

easily manage filer accounts.153

Separate optional APIs will be provided 

so that filers may view individuals 

authorized for a CIK, add individuals, 

remove individuals, and change roles 

for individuals.154 Collectively, these 

APIs should enable filing agents and 

other entities that support large 

numbers of filers to rapidly and 

efficiently manage individual 

authorizations and roles for those filers. 

f. APIs To Send Delegation Invitations, 

Request Delegation Invitations, and 

View Delegations 

As discussed above, commenters 

requested the addition of optional APIs 

to replicate dashboard functionality to 

allow filing agents and other entities 

that support large numbers of registrants 

to more easily manage filer accounts.155

Separate optional APIs will be provided 

to allow filers to send delegation 

invitations to prospective delegated 

entities, request delegation invitations 

from prospective delegating filers, and 

view delegations currently in place 

(including both delegations received 

from filers and also delegations 

provided to delegated entities). 

Collectively, these optional APIs should 

enable filing agents and other entities 

that support large numbers of filers to 

manage delegations rapidly and 

efficiently for those filers. 

g. APIs To View Filer Account 

Information, Generate CCC, and Create 

Custom CCC 

Several commenters requested the 

addition of an optional API to make 

available on a machine-to-machine basis 

the same functionality that is currently 

provided within the ‘‘Retrieve/Edit 

Data’’ section of the EDGAR Filing 

website.156 That functionality includes, 

but is not limited to, the ability to view/ 

edit filer account information such as 

the filer’s name, contact information, 

and corporate information like State of 

incorporation and fiscal year-end, view 

the filer’s current account balances and 

request the return of unused funds, and 

change the filer’s password or CCC. As 

part of the transition to EDGAR Next, 

some of this functionality will be shifted 

to the dashboard, such as the filer’s 

EDGAR POC. In addition, the fee-related 

aspects of this functionality raise unique 

technical challenges that make 

providing APIs for those functions more 

difficult due to the current systems and 

processes surrounding payment and fee 

information.157 For those reasons, 

separate APIs will not be added at this 

time for each of the functions currently 

provided in the ‘‘Retrieve/Edit Data’’ 

section of the EDGAR Filing website. 

To address commenter concerns, 

however, a ‘‘view filer account 

information API,’’ as well as a ‘‘generate 

CCC API’’ and a ‘‘create custom CCC 

API,’’ will be added. The optional view 

filer account information API will allow 

filers to view the filer’s name, contact 

information, CCC, CIK type (company, 

single-member company, or individual), 

and next confirmation date. The 

optional generate CCC and create 

custom CCC APIs will allow filers to 

generate a new CCC at any time to 

enhance filer security without causing 

filing delays. 

h. Enrollment API 

To facilitate the requirement that 

existing filers enroll in EDGAR Next, an 

optional API designed to automate the 

enrollment process will be added. As 

stated in the Proposing Release, filers 

may enroll in EDGAR Next either 

through, (a) manual enrollment of single 

accounts on an account-by-account 

basis or (b) enrollment of multiple 

accounts simultaneously, by completing 

and uploading a spreadsheet of up to 

100 filers (100 rows) per bulk 

enrollment. Several commenters 

expressed concerns regarding the 

volume and complexity of enrollment 

and requested that some form of 

automation or increased flexibility be 

provided regarding the enrollment 

process.158 The ‘‘enrollment API’’ 

should help address these concerns by 

streamlining the enrollment process. 

2. API Tokens 

For filers that opt to connect to APIs, 

filer API tokens and user API tokens if 

the relevant API requires presentation of 

a user API token, will be required by the 

EDGAR Filer Manual as amended, as 

discussed in the Proposing Release. The 

use of tokens to connect to optional 

APIs is a security requirement designed 

to minimize the potential for 

unauthorized access to filers’ accounts 

on EDGAR. 

As discussed in the Proposing 

Release, the EDGAR Filer Manual will 

be amended to require that filers that 

connect to the optional APIs have a 

technical administrator generate a filer 

API token on the dashboard to 

authenticate the filer. The filer API 

token will remain valid for up to one 

year. In a change to what was discussed 

in the proposal, a filer will be allowed 

to use its delegated entities’ filer API 

tokens and API connections (and rely 

upon its delegated entities’ technical 

administrators), so long as the filer’s 

delegated entity has authorized at least 

two technical administrators pursuant 

to paragraph (d)(3) of Rule 10 and the 

individual at the filer using its delegated 

entity’s filer API tokens and API 

connections provides a valid user API 

token if the relevant API requires 

presentation of a user API token, as set 

forth below. Further, as discussed in the 

Proposing Release, the EDGAR Filer 

Manual will be amended to require that 

an individual user or account 

administrator generate a user API token 

on the dashboard to authenticate 

herself. In a change to the discussion in 

the Proposing Release indicating that 

the EDGAR Filer Manual would require 

that the user API token would remain 

valid for up to one year so long as the 

user logged into EDGAR at least every 

30 days, the EDGAR Filer Manual will 

specify that the user API token will 

remain valid for 30 days from the time 

the token is generated. 

One commenter recommended that a 

filer be able to use the filer API token 

generated by the filer’s delegated 

entity.159 This suggestion will be 


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use its filer token, an employee of the filing 

software provider would not typically be involved 

to provide their user token. One solution would be 

to allow the registrant’s authorized user to use their 

user token with the delegated filing software’s filer 

token.’’). 

160See XBRL II Comment Letter (‘‘We also suggest 

that the Commission give users the ability to see 

information about the token, for example what is 

the upcoming expiration date. This could be 

executed through an API that provides visibility 

into whether the token should work, and if it is not 

functional, an explanation as to why it is not 

working.’’). 

161See, e.g., XBRL II Comment Letter (‘‘[T]he 

requirement to log into an EDGAR website, 

interactively, every 30 days means that many 

Section 16 reporting owners will be continuously 

inactivated.’’); SIFMA Comment Letter (‘‘[W]e 

recommend that EDGAR Next access credentials not 

be removed for mere inactivity, which the 

Commission indicates would happen with API 

tokens that are not used during a 30 day period.’’); 

Workiva Comment Letter (‘‘According to our 

customer survey, about 72% of the respondents 

indicated that [the 30-day login requirement for 

user API tokens] poses a significant burden or risk 

to their filing teams. We strongly recommend that 

the Commission eliminate this requirement.’’). 

162See XBRL II Comment Letter (‘‘[W]e are 

concerned about the multiple layers of 

requirements for the token API, for example, the 

expiration and 30-day login requirements, which 

will be challenging, particularly for sporadic 

filers.’’). 163See Chris V. Comment Letter (‘‘In the vein of 

additional security, the proposal as written also 

currently suggests requiring monthly logins to 

maintain access to an API access code which is 

open for one year. I feel this could be considered 

heavyhanded in comparison to the fairly lax 

standards which exist today, but I do think it’s 

worth the additional security and expectation from 

those submitting data.’’). 

164See XBRL II Comment Letter (‘‘[W]e are 

concerned about the multiple layers of 

requirements for the token API, for example, the 

expiration and 30-day login requirements, which 

will be challenging, particularly for sporadic 

filers.’’). 

165See Workiva Comment Letter (indicating that 

the SEC should allow an organizational user token 

that represents the organization as a whole and that 

could be managed the same way as an individual 

user API token). 

166See Comment Letter of Martin Francisco 

(November 21, 2023) (‘‘Would it be deemed 

permissible to use a single user token belonging to 

the administrator of a third-party filing solution to 

submit filings created by independent users of that 

third-party filing solution? Such a deployment 

would make it easier for users of that third-party 

solution (no individual token management 

needed).’’). 

implemented to make the optional APIs 

more accessible for smaller filers. As 

discussed above, filers may use their 

delegated entity’s API connections and 

filer API tokens so long as the delegated 

entity has authorized at least two 

technical administrators pursuant to 

paragraph (d)(3) of Rule 10. Filers that 

do so will not need to authorize their 

own technical administrators or obtain 

and maintain their own filer API tokens. 

Individuals at these filers must, 

however, supply their own user API 

tokens, if the relevant API requires 

presentation of a user API token. As a 

result, smaller filers that may not have 

the resources to develop API 

connections or employ their own 

technical administrators, but who 

nevertheless would like their personnel 

to interact with EDGAR through APIs, 

may use the APIs that their delegated 

entity develops and maintains. 

Another commenter expressed 

concern that expiring API tokens could 

frustrate the ability of filers to plan 

ahead to make filings and suggested that 

the Commission provide an API to allow 

filers to programmatically check 

expiration dates for relevant filer API 

tokens and user API tokens.160 As 

discussed further above, an optional 

filing credentials API will be offered so 

that filers can check filing credentials, 

including information regarding API 

token expiration dates and account 

confirmation deadlines. 

Many commenters objected to the 30- 

day login requirement for the user API 

token discussed in the proposal and 

stated that it would be especially 

burdensome for infrequent filers.161 One 

commenter also expressed concerns 

about the complexity and multiple 

layers of requirements contemplated for 

user API tokens, citing the one-year 

validity period and 30-day login 

requirements.162 Another commenter 

supported the 30-day login requirement 

as being justified in terms of providing 

additional security.163

We considered these comments as 

well as the need to enhance system 

security. As a result, in a change to what 

was discussed in the Proposing Release, 

the EDGAR Filer Manual as amended 

will specify that the user API token will 

expire 30 days after the individual 

generates the token. The Proposing 

Release by contrast contemplated that 

the user API token would remain valid 

for one year so long as the user logged 

into the dashboard every 30 days. Thus, 

rather than logging in every 30 days to 

keep the user API token active, as 

discussed in the Proposing Release, the 

individual is required to log in every 30 

days to generate a new user API token. 

The shorter duration of the user API 

token will enhance the security of APIs, 

especially in light of the annual 

duration of the filer API token. Shorter 

validity periods and more frequent 

expiration dates limit the risk exposure 

of a token being lost or stolen during the 

validity period, and thus more frequent 

expiration dates are generally preferable 

from a security perspective. Separately, 

the 30-day duration of the user API 

token avoids the potential confusion 

posed by a token that persists for one 

year only if the user logs into EDGAR 

every 30 days, a concern expressed by 

one commenter noted above.164 We note 

that an optional API will be offered, as 

requested by commenters and discussed 

above, to allow filers easily to retrieve 

the expiration dates of the filer API 

token and user API token. 

While we understand the concerns 

raised by commenters, we do not think 

it is unduly burdensome for section 16 

and other periodic filers who choose to 

make submissions through APIs to log 

into the dashboard and generate a new 

user API token once per month or 

otherwise prior to making an infrequent 

filing. Further, as is the case currently, 

the individual making the submission 

need not be the filer itself. Section 16 

and other periodic filers could authorize 

through powers of attorney relevant 

individuals at their filing agents or other 

representatives as account 

administrators, eliminating the need for 

the section 16 or other periodic filer to 

obtain individual account credentials or 

otherwise interact with the dashboard. 

Alternatively, section 16 and other 

periodic filers could delegate authority 

to file to one of these entities (so long 

as that entity has an EDGAR account), 

thereby eliminating the need for the 

section 16 filer herself to log into the 

dashboard to generate user API tokens. 

In addition, as noted elsewhere in this 

release, generating a user API token is 

a straightforward process accomplished 

on the dashboard, and we estimate that 

a user API token could be generated 

within approximately one minute of 

logging into the dashboard. Moreover, 

the ability of a filer to authorize 

multiple account administrators and 

users, each with a user API token 

expiring at a different time, lessens 

concerns about the need to generate a 

new user API token for a particular user 

when a filing deadline is approaching. 

A commenter suggested that the SEC 

allow the use of ‘‘organizational user 

tokens’’ that would represent the filer as 

a whole, as opposed to identifying a 

specific individual.165 Similarly, 

another commenter suggested that filers 

using third-party filing software should 

be able to submit filings by presenting 

a user API token belonging to an 

individual at the third-party filing 

software company, so that the 

individual who was making the filing 

would not need to obtain a user API 

token to identify herself.166 We decline 

to implement these suggestions because 

they would frustrate the Commission’s 

objective of identifying the individual 

making the filings and taking actions on 

EDGAR through APIs. 

Other commenters suggested that API 

tokens should have no expiration dates 

or alternately should be automatically 


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167See XBRL II Comment Letter (‘‘We recommend 

never letting the token expire, or at a minimum 

setting a longer time for the token expiration 

period.’’); Comment Letter of Jacob Halstead 

(January 17, 2024) (suggesting the SEC should 

‘‘allow applications to . . . renew the token without 

user interaction.’’). 

168See Workiva Comment Letter (‘‘We feel that 

the proposed filer and user tokens system may be 

less secure in practice than anticipated. Since many 

registrant and reporting owner filings are handled 

by multiple filing agents and due to additional 

administration and management requirements in 

the EDGAR Next proposal, these long-lived tokens 

will likely be shared amongst multiple 

organizations and may provide no actual assurance 

that a filing is being submitted by the user 

associated with the token.’’). 

169EDGAR will be enhanced to ensure that when 

a Form ID PDF is created from the dashboard, that 

PDF will not contain hyperlinks that may interfere 

with the upload of the document to EDGAR. To be 

clear, this technical change is unrelated to the 

amendments to Rule 10. 

170Compare current EDGAR Filer Manual, 

Volume I, at section 5 (‘‘Filers must maintain 

accurate company information on EDGAR, 

including but not limited to a filer’s current name, 

business mailing address, and business email 

address.’’) with amended EDGAR Filer Manual, 

Volume I, at section 4 (‘‘As required by Rule 

10(d)(5) of Regulation S–T, 17 CFR 232.10(d)(5), 

filers must maintain accurate and current company 

information on EDGAR concerning the filer’s 

account, including but not limited to accurate 

contact information and corporate information, if 

relevant.’’). 

171Compare current EDGAR Filer Manual, 

Volume I, at section 4 (‘‘Filers must securely 

maintain all EDGAR access codes and limit the 

number of persons who possess the codes. EDGAR 

access codes include the password, passphrase, 

CCC, and password modification authorization code 

renewed upon expiration.167 Although 

we acknowledge commenters’ concerns 

that limiting the duration of API tokens 

could be inconvenient, we balance those 

concerns against our goals of 

maintaining EDGAR security by 

requiring authenticating credentials to 

be updated periodically via multifactor 

authentication, and by requiring new 

tokens periodically to avoid 

unauthorized use of a persistent token. 

A one-year validity period for filer API 

tokens is consistent with current 

EDGAR security requirements, which 

require passwords to be changed once 

per year before they expire. In addition, 

a 30-day validity period for user API 

tokens will reduce the risk that a longpersistent token will be compromised. 

One commenter suggested that filers 

and filing agents may in practice share 

filer API tokens and user API tokens 

across multiple organizations with the 

result that submissions will not be as 

secure as anticipated and not 

necessarily be associated with the 

individual who generated the user API 

token.168 To be clear, Rule 10 as 

amended requires that individuals 

access EDGAR by logging in with their 

own Login.gov individual account 

credentials and employ multifactor 

authentication. The EDGAR Filer 

Manual as amended will further require 

that user API tokens be associated with 

the individual logging into EDGAR. As 

discussed in this release, the 

Commission seeks to trace submissions 

to the individual who logs into EDGAR 

with individual account credentials and 

completes multifactor authentication. 

For APIs, presentation of the 

individual’s user API token allows the 

Commission to identify who makes each 

submission or takes action on EDGAR, 

a primary goal of this rulemaking. We 

agree that the potential scenario 

described by the commenter 

compromises EDGAR security, and we 

reiterate that we expect filers to comply 

with the requirements of Rule 10 and 

the EDGAR Filer Manual as amended. 

EDGAR Next provides filers flexibility 

to manage the security tokens required 

for connection to optional APIs. Filers 

may generate an unlimited number of 

filer API tokens on the dashboard. Filers 

may use the filer API tokens and API 

connections of their delegated entities. 

With respect to user API tokens, filers 

have several options to authorize up to 

500 individuals to make submissions. 

Filers may authorize up to 20 account 

administrators in total (including 

individuals not employed at the filer or 

its affiliates through notarized powers of 

attorney), and those account 

administrators may authorize up to 500 

users, all of whom would be authorized 

to make submissions on behalf of the 

filer and would be able to generate user 

API tokens. Filers may delegate 

authority to filing agents or any other 

EDGAR account to file on their behalf, 

and those entities may each have up to 

20 account administrators and 500 

users. Any of these individuals would 

be able to generate a user API token and 

make submissions on behalf of the filer 

in compliance with EDGAR Next. 

F. Final Amendments to Rules and 

Forms 

1. Rule 10 of Regulation S–T 

The Commission proposed to amend 

Rule 10 of Regulation S–T to add new 

paragraph (d) and to make certain 

clarifying and conforming changes in 

paragraph (b) and in the note to Rule 10. 

We did not receive any comments 

concerning the proposed amendments 

to Rule 10. We received one comment 

peripheral to paragraph (b)(2) of Rule 10 

requesting that the technical process of 

uploading PDFs to EDGAR be improved. 

As discussed in more detail below, that 

improvement to EDGAR will be 

made.169

We are adopting, largely as proposed, 

amendments to Rule 10 of Regulation S– 

T to add paragraph (d). New paragraphs 

(d)(1) through (4) are discussed in full 

above. As discussed above, we are 

adopting paragraph (d)(3) of Rule 10 

with a few slight modifications from the 

proposal: paragraph (d)(3) of Rule 10 

will refer to filers that ‘‘connect to’’ APIs 

rather than filers that ‘‘use’’ APIs, and 

will not apply to a filer that has 

delegated authority to file on the 

dashboard to a delegated entity that is 

in compliance with the rule’s 

requirements. In addition, as noted 

above, minor revisions to paragraph 

(d)(2) as proposed were made to the 

paragraph as adopted to clarify that each 

individual or single-member company 

electronic filer must authorize and 

maintain at least one individual as an 

account administrator to manage its 

EDGAR account. 

We are adopting amendments, as 

proposed, to add new paragraph (d)(5) 

of Rule 10 to require that the filer, 

through its authorized account 

administrators, maintain accurate and 

current information on EDGAR 

concerning the filer’s account, including 

but not limited to accurate corporate 

information and contact information, 

such as mailing and business addresses, 

email addresses, and telephone 

numbers. This constitutes an ongoing 

obligation for the filer to update its 

information on EDGAR as necessary. 

New paragraph (d)(5) is analogous to the 

existing requirements set forth in the 

EDGAR Filer Manual, Volume I to 

maintain accurate company information 

on EDGAR, which we are amending 

accordingly to reference new paragraph 

(d)(5).170 The requirement in paragraph 

(d)(5) of Rule 10 will provide greater 

assurance to Commission staff and the 

public about the accuracy of the filer’s 

information contained in EDGAR. 

We are also adopting amendments, as 

proposed, to add paragraph (d)(6) of 

Rule 10, which requires the filer, 

through its authorized account 

administrators, to securely maintain 

information relevant to the ability to 

access the filer’s EDGAR account, 

including access through any EDGAR 

API. This requirement is designed to 

ensure that information relevant to the 

ability to access the filer’s account, such 

as individual account credentials and 

API tokens, is securely maintained and 

not publicly exposed or otherwise 

compromised. New paragraph (d)(6) of 

Rule 10 is analogous to requirements set 

forth in the EDGAR Filer Manual, 

Volume I to securely maintain EDGAR 

access and to maintain accurate 

company information on EDGAR.171


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(PMAC).’’) with amended EDGAR Filer Manual, 

Volume I, at section 3 (‘‘Each applicant or filer may 

only authorize to act on its behalf on EDGAR those 

individuals who have obtained individual account 

credentials through Login.gov. . . . Individual 

account credentials are intended for the use of the 

individual who obtained them to allow 

identification of the individual taking action on 

EDGAR. Individual account credentials must not be 

shared with other individuals.’’). 

172Compare current paragraph (b) of Rule 10 of 

Regulation S–T (‘‘Each registrant, third party filer, 

or filing agent must, before filing on EDGAR . . .’’ 

with amended paragraph (b) of Rule 10 of 

Regulation S–T (‘‘Each electronic filer must, before 

filing on EDGAR . . .’’). 

173Compare current paragraph (b)(2) of Rule 10 

of Regulation S–T (‘‘File . . . a notarized document, 

signed by the applicant . . .’’ with amended 

paragraph (b)(2) of Rule 10 of Regulation S–T (‘‘File 

. . . a notarized document, signed by the electronic 

filer or its authorized individual . . .’’). 

174See EDGAR Filer Manual, Volume I, at section 

3(b). 

175See Toppan Merrill Comment Letter 

(‘‘Additional detail around the requirements for 

PDF documents under 232.10(b)(2) would be 

helpful (e.g., what PDF formats acceptable [sic], is 

the PDF required to be searchable, are hyperlinks 

allowed, etc.) Currently, the Form ID application 

contains many URLs, which when printed to PDF, 

electronically signed and uploaded do not pass 

validation. It would be helpful to hide these URLs 

from the printed version of the Form ID 

authentication document.’’). 

176See EDGAR Filer Manual, Volume II, at 

section 5.2.3.2 (discussing EDGAR validation 

requirements for PDFs). 

177As adopted, the note to Rule 10 states: ‘‘The 

Commission staff carefully review each Form ID 

application, and electronic filers should expect that 

the Commission staff will require sufficient time to 

review the Form ID upon its submission. Therefore, 

any applicant seeking EDGAR access is encouraged 

to submit the Form ID for review well in advance 

of the first required filing to allow sufficient time 

for staff to review the application.’’ Current staff 

guidelines regarding the minimum time needed for 

Commission staff to review Form ID can be found 

in the ‘‘Prepare and Submit my Form ID 

Application’’ section of the ‘‘EDGAR — How Do I’’ 

FAQs, at https://www.sec.gov/submit-filings/filersupport-resources/how-do-i-guides/prepare-submitmy-form-id-application. 

The Commission is also adopting, 

substantially as proposed, amendments 

to Rule 10 to make certain clarifying and 

conforming changes. Paragraph (b) of 

Rule 10 is being revised to refer to ‘‘each 

electronic filer’’ required to submit 

Form ID before filing on EDGAR, 

instead of ‘‘each registrant, third party 

filer, or filing agent.’’ 172 This change is 

not intended to alter the scope of who 

is subject to paragraph (b) of Rule 10, 

but instead clarifies that all new 

electronic filers are required to submit 

Form ID for review and approval by 

Commission staff before they may file 

on EDGAR. 

In addition, we are adopting as 

proposed an amendment to paragraph 

(b)(2) of Rule 10, which currently states 

that an authenticating document for 

Form ID must be signed by the 

applicant, to also state that the 

authenticating document may be signed 

by an authorized individual of the 

applicant.173 This final amendment is 

intended to conform the language in 

paragraph (b)(2) of Rule 10 with the text 

of the EDGAR Filer Manual, which 

provides that the authenticating 

document shall be signed by an 

authorized individual, including a 

person with a relevant power of 

attorney.174 We proposed to separately 

amend paragraph (b) of Rule 10 of 

Regulation S–T to require Form ID to be 

completed by an individual authorized 

by the electronic filer as its account 

administrator. In a modification from 

the proposal, however, as discussed in 

section II.B.1.a, it will not be necessary 

for Form ID to be completed or 

submitted by one of the applicant’s 

prospective account administrators. 

Thus, that proposed amendment to 

paragraph (b) of Rule 10 is not being 

adopted. 

As noted above, we received one 

comment requesting additional details 

concerning the PDF requirements for 

Form ID authenticating documents 

required to be uploaded to EDGAR 

pursuant to proposed paragraph (b)(2) of 

Rule 10.175 The commenter stated that 

Form ID authenticating documents 

could not be successfully uploaded to 

EDGAR because those PDFs contained 

hyperlinks which prevented the 

documents from being accepted by 

EDGAR. PDF documents required to be 

uploaded pursuant to paragraph (b)(2) of 

Rule 10 are subject to the same EDGAR 

validation requirements that apply to all 

PDF documents uploaded to EDGAR, 

including prohibitions on active content 

(e.g., embedded JavaScript) and external 

references (hyperlinks, etc.).176 Any 

URLs contained in PDFs must be in 

plain text. To facilitate the process of 

uploading PDFs to EDGAR pursuant to 

paragraph (b)(2) of Rule 10, EDGAR will 

be enhanced to ensure that when a Form 

ID authenticating document PDF is 

created from the dashboard, that PDF 

will not contain hyperlinks. 

Finally, we are adopting revisions to 

the note to Rule 10 largely as proposed 

to state that the Commission staff 

carefully review each Form ID 

application and that filers should expect 

that the Commission staff will require 

sufficient time to approve and review 

the Form ID. For clarity, the final 

amendments express this as an 

affirmative statement (‘‘filers should 

expect that the Commission staff will 

require sufficient time to review the 

Form ID’’) as opposed to how this 

concept was proposed (‘‘filers should 

not assume that the Commission staff 

will automatically approve the Form 

ID’’). Therefore, the final amendments 

provide that filers should submit Form 

ID ‘‘well in advance’’ of their first 

required filing.177 We believe this 

revised language makes clear that 

Commission staff need an appropriate 

amount of time to review the Form ID. 

Due to the frequently high volume of 

Form ID applications submitted for 

Commission staff review, potential 

applicants should allow sufficient time 

for the review process to be conducted 

in the event that staff is concurrently 

reviewing a high volume of 

applications. 

2. Rule 11 of Regulation S–T 

As proposed, we are adopting 

amendments to Rule 11 of Regulation S– 

T, ‘‘Definitions of terms used in this 

part,’’ to add and define new terms and 

update the definitions of certain existing 

terms. The amendments include terms 

and definitions specific to the rule and 

form amendments that delineate how 

individuals and entities access, file on, 

and manage EDGAR accounts. 

Under the final amendments, certain 

terms define the new roles for 

individuals under EDGAR Next. Those 

roles are as follows: 

‘‘Account administrator’’ means the 

individual that the filer authorizes to 

manage its EDGAR account and to make 

filings on EDGAR on the filer’s behalf. 

The designation of an account 

administrator helps to ensure that only 

authorized persons are able to file and 

take other actions on behalf of the filer. 

‘‘Authorized individual’’ means an 

individual with the authority to legally 

bind an entity or individual for 

purposes of Form ID, or an individual 

with a power of attorney from an 

individual with the authority to legally 

bind an entity or individual for 

purposes of Form ID. The adopted 

definition specifies that the power of 

attorney document must clearly state 

that the individual receiving the power 

of attorney has general legal authority to 

bind the entity or individual or specific 

legal authority to bind the entity or 

individual for purposes of Form ID. 

‘‘Delegated entity’’ means a filer that 

another filer authorizes on the 

dashboard to file on its behalf. As itself 

a filer, a delegated entity is subject to all 

applicable rules for filing on EDGAR. 

Delegated entities are not permitted to 

further delegate authority to file for the 

delegating filer, nor are they permitted 

to take action on the delegating filer’s 

dashboard. 

‘‘Filing agent’’ means any person or 

entity engaged in the business of making 

submissions on EDGAR on behalf of 

filers. As discussed above in section 

II.C., to act as a delegated entity for a 


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178See DFIN Comment Letter; Toppan Merrill 

Comment Letter. 

179See DFIN Comment Letter (‘‘ ‘Filer API Token’ 

and ‘User API Token’ should be defined.’’). 

180Compare current Rule 10(b) (providing that 

each registrant, third party filer, or agent seeking 

EDGAR access must submit Form ID) with Rule 

10(b) as adopted (providing that each electronic 

filer seeking EDGAR access must submit Form ID). 

181The applicant may print the form to PDF and 

need not print a physical hard copy of the form. 

182The term ‘‘authorized individual’’ is defined 

in the EDGAR Filer Manual, Volume I as well as 

Rule 11, as amended. 

183For example, if an applicant represents that it 

has acquired or otherwise assumed control of the 

filer listed on the existing EDGAR account, then the 

applicant must also supply documents to 

Commission staff to establish the legal transition 

from the filer on record in EDGAR to the applicant 

claiming authority to file on the existing EDGAR 

account. 

184See supra text accompanying and following 

note 70. 

185The LEI is a global, 20-character, 

alphanumeric, identifier standard that uniquely and 

unambiguously identifies a legal entity. Initially 

developed by the International Organization for 

Standardization as ISO 17442, the LEI is 

nonproprietary and the LEI data is made publicly 

available under an open license. The LEI is used 

worldwide in the private and public sectors and, in 

certain jurisdictions, including the United States, is 

used for regulatory reporting. In some cases, the LEI 

can be used to identify the filer of a particular 

report, as well as entities related to the filer, such 

as its subsidiaries or parents. The Commission and 

eight other Federal agencies recently proposed 

establishing joint data standards, which would 

include LEI, under the Financial Data Transparency 

Act of 2022. See Financial Data Transparency Act 

Joint Data Standards, Release No. 33–11295 

(August 2, 2024) [89 FR 67890 (August 22, 2024)]. 

filer, a filing agent must be a filer with 

an EDGAR account. 

‘‘Single-member company’’ describes 

a company that only has a single 

individual who acts as the sole equity 

holder, director, and officer (or, in the 

case of an entity without directors and 

officers, holds position(s) performing 

similar activities as a director and 

officer). 

‘‘Technical administrator’’ means an 

individual that the filer authorizes on 

the dashboard to manage the technical 

aspects of the filer’s connection to 

EDGAR APIs on the filer’s behalf. 

‘‘User’’ means an individual that the 

filer authorizes on the dashboard to 

make submissions on EDGAR on the 

filer’s behalf. 

Other terms identify new applications 

and upgrades to access and maintain 

filers’ accounts on EDGAR, including 

the following: 

‘‘Application Programming Interface’’ 

(API) means a software interface that 

allows computers or applications to 

communicate with each other. 

‘‘Dashboard’’ means an interactive 

function on EDGAR where filers manage 

their EDGAR accounts and where 

individuals that filers authorize may 

take relevant actions for filers’ accounts. 

‘‘Individual account credentials’’ 

means credentials issued to individuals 

for purposes of EDGAR access, as 

specified in the EDGAR Filer Manual, 

and used by those individuals to access 

EDGAR. The EDGAR Filer Manual as 

amended specifies that individual 

account credentials must be obtained 

through Login.gov, a sign-in service of 

the United States Government that 

employs multifactor authentication. 

The final amendments also update or 

delete outdated terminology from 

certain definitions in Rule 11, such as 

references to ‘‘telephone sessions’’ in 

the definition of ‘‘direct transmission.’’ 

Although some filers may still use dialup internet to access EDGAR, we expect 

that nearly all filers currently rely on 

broadband, cable, or other internet 

technologies. 

Finally, we are adopting amendments 

to update the definition of ‘‘EDGAR 

Filer Manual’’ to more clearly describe 

its contents. Rule 11 currently describes 

the ‘‘EDGAR Filer Manual’’ as ‘‘. . . 

setting out the technical format 

requirements for an electronic 

submission.’’ The EDGAR Filer Manual 

has been updated over time, however, to 

include additional requirements for 

filers, including those pertaining to 

EDGAR access, maintaining EDGAR 

company information, and submitting 

online filings. Accordingly, we are 

updating the EDGAR Filer Manual 

definition to indicate the inclusion of 

these procedural requirements. We 

believe that the final amendments to the 

definition will better inform filers of the 

scope of the EDGAR Filer Manual 

requirements. 

We received three comments on the 

proposed definitions in the Proposing 

Release. Two commenters agreed that 

the proposed amendments to the 

definitions in Rule 11 were 

appropriate.178 One of the commenters 

also requested that the terms ‘‘Filer API 

Token’’ and ‘‘User API Token’’ be 

defined.179 We do not think it is 

necessary to amend Regulation S–T to 

provide definitions of ‘‘Filer API 

Token’’ and ‘‘User API Token’’ because 

those terms are not referenced in 

Regulation S–T. Further, we are making 

one change to the definition of 

Technical Administrator to accord with 

the change from the word ‘‘use’’ in 

proposed paragraph (d)(3) of Rule 10 to 

the word ‘‘connect’’ in adopted 

paragraph (d)(3) of Rule 10. The word 

‘‘connect’’ will similarly be substituted 

for the word ‘‘use’’ in the definition of 

technical administrator for the reasons 

given above. 

3. Form ID 

Form ID is an online fillable form that 

must be completed and submitted to the 

Commission by individuals, companies, 

and other organizations that seek access 

to file electronically on EDGAR.180

Among other things, Form ID seeks 

information about the identity and 

contact information of the applicant. 

The applicant is required to print 181 the 

completed online Form ID application, 

obtain the notarized signature of the 

applicant’s authorized individual 182 on 

the printed document, and upload the 

signed notarized document (the Form ID 

authentication document) to EDGAR to 

confirm the authenticity of the 

application. In certain cases, applicants 

may also be required to upload 

additional documentation to assist 

Commission staff in determining the 

nature and legitimacy of the 

application.183

We are adopting amendments to Form 

ID largely as proposed to include 

changes to information required to be 

reported on the form as well as 

technical changes. As a departure from 

what we contemplated in the Proposing 

Release, however, and as discussed 

above, it will not be necessary for Form 

ID to be completed or submitted by one 

of the applicant’s prospective account 

administrators. 

As outlined above, the final 

amendments to Form ID will require an 

applicant for EDGAR access to provide 

certain additional information, 

including: 

(1) Designating on Form ID specific 

individuals the applicant authorizes to 

act as its account administrators to 

manage its EDGAR account on a 

dedicated dashboard on EDGAR. 

Applicants will generally be required to 

authorize at least two account 

administrators, although individuals 

and single-member companies will only 

be required to authorize at least one 

account administrator. If a prospective 

account administrator is not (1) the 

applicant (in the case of an individual 

applicant) or (2) an employee of the 

applicant or its affiliate (in the case of 

a company applicant), the applicant will 

also be required to disclose the 

prospective account administrator’s 

employer and CIK, if any, and provide 

a notarized power of attorney to 

authorize the individual to manage the 

applicant’s EDGAR account as an 

account administrator. As discussed 

above, as a departure from the proposal, 

amended Form ID will also include 

information to alert applicants that 

EDGAR will by default designate the 

first account administrator listed on 

Form ID as the filer’s EDGAR POC.184

(2) The applicant’s Legal Entity 

Identifier 185 (‘‘LEI’’) number, if any. 


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186See DFIN Comment Letter (‘‘The ‘Violations of 

federal or state securities laws’ section in the 

proposal has a Yes or No question. When yes is 

selected a message [says] ‘If you indicate ‘Yes’, the 

SEC staff may contact you to determine your 

eligibility for EDGAR access.’ However, the ‘Is the 

company in good standing in its state or country of 

incorporation?’ section does not provide any 

additional information when ‘No’ is selected. If ‘No’ 

is selected what actions are taken by the SEC?’’) 

187The filer will nevertheless need to submit a 

COUPDAT to update its existing corporate and 

contact information on EDGAR (other than the 

filer’s account administrator information) if the 

Form ID is granted. As they presently do, brokerdealers will submit a Form BD amendment to 

FINRA to update their corporate and contact 

information. 

188The EDGAR Filer Manual currently provides 

guidance regarding what documents are sufficient 

to establish the applicant’s authority. See EDGAR 

Filer Manual, Volume I. 

189Amended Form ID will include a section titled 

‘‘Important information’’ that will include the 

following warning: ‘‘Misstatements or omissions of 

fact in connection with an application for EDGAR 

access and/or in a submission on EDGAR may 

constitute a criminal violation under 18 U.S.C. 1001 

and 1030 and/or a violation of other criminal and 

civil laws. If the SEC has reason to believe that an 

application for EDGAR access and/or a submission 

on EDGAR is misleading, manipulative, and/or 

unauthorized, the SEC may prevent acceptance or 

dissemination of the application/submission and/or 

prevent future submissions or otherwise remove a 

filer’s access to EDGAR pursuant to Rule 15 of 

Regulation S–T, 17 CFR 232.15.’’ 

Applicants that have not yet obtained an 

LEI will not be required to do so to 

submit Form ID. For those applicants 

that have obtained an LEI, inclusion of 

this information will facilitate the 

ability of Commission staff to link the 

identity of the applicant with 

information reported on other filings or 

sources that are currently or will be 

reported elsewhere in the future, if LEIs 

become more widely used by regulators 

and the financial industry. 

(3) Providing more specific contact 

information about the filer, and the 

filer’s account administrator(s), 

authorized individual (the individual 

authorized to sign Form ID on the filer’s 

behalf, as defined in the EDGAR Filer 

Manual), and billing contact (including 

mailing, business, and billing 

information, as applicable). More 

specific contact information will allow 

Commission staff to reach account 

administrators, the authorized 

individual, and billing contacts 

associated with the filer when 

necessary. 

To streamline the form, some of the 

specific contact information that was 

proposed to be collected on Form ID 

will not be included. For example, Form 

ID will not require secondary phone 

numbers or email addresses in addition 

to the filer’s mailing and business 

addresses. We believe that the 

additional contact information we will 

collect on amended Form ID will be 

sufficient to meet Commission staff’s 

needs. Similarly, although we proposed 

amendments to the filer’s mailing 

address that would allow filers to input 

‘‘care of’’ information so that a company 

applicant could list a filing agent, for 

example, we are not amending Form ID 

to implement that change. We believe 

that including a separate address line 

for ‘‘care of’’ information could 

encourage applicants to list the names 

of specific individuals who might not 

want to be publicly listed in EDGAR as 

part of the filer’s mailing address. The 

Form ID fields related to the filer’s 

mailing address will continue to have 

multiple street address lines, as 

proposed, which we believe will 

provide sufficient opportunity for 

applicants that wish to include such 

information to do so. 

(4) Specifying whether the applicant, 

its authorized individual, person 

signing a power of attorney (if 

applicable), account administrator, or 

billing contact has been criminally 

convicted as a result of a Federal or 

State securities law violation, or civilly 

or administratively enjoined, barred, 

suspended, or banned in any capacity, 

as a result of a Federal or State 

securities law violation. Information 

about whether the applicant or certain 

individuals named on Form ID may be 

subject to relevant bars and prohibitions 

(including but not limited to officer and 

director bars, prohibitions from 

associating with brokers, dealers, 

investment advisers, and/or other 

securities entities, and bars from 

participation in certain industries) will 

allow Commission staff to determine 

whether such bars or prohibitions are 

relevant to the application for EDGAR 

access. Individuals disclosing the 

existence of a criminal conviction, or 

civil or administrative injunction, bar, 

suspension, or ban may be contacted by 

Commission staff to determine the 

applicant’s eligibility for EDGAR access. 

(5) Indicating whether the applicant, 

if a company, is in good standing with 

its State or country of incorporation. 

Good standing is a term widely used by 

State divisions of corporations and/or 

secretaries of State to refer generally to 

whether a company is legally authorized 

to do business in the relevant State (or 

country). 

One commenter inquired what action 

the SEC will take if the Form ID 

applicant indicates that it is not in good 

standing with its State or country of 

incorporation.186 Although the lack of 

good standing will not prevent a 

company from obtaining EDGAR access, 

this information could be relevant in 

determining whether it may be 

appropriate for the staff to review 

additional documentation as part of its 

assessment of the application. 

(6) Requiring submission of a new 

Form ID for an existing filer that 

indicates that it has: (i) lost electronic 

access to its existing CIK account or (ii) 

is the legal successor of the filer named 

on the existing CIK account but did not 

receive access from that filer. As a 

technical change from the proposal, 

amended Form ID will refer to 

applicants that are ‘‘the legal successor 

of the filer named on the existing CIK 

account but did not receive access from 

that filer’’ as opposed to applicants that 

‘‘assumed legal control of the filer listed 

on the existing CIK account but did not 

receive EDGAR access,’’ as proposed. 

Currently, applicants seeking to 

obtain control of an existing EDGAR 

account are required to submit certain 

summary information but are not 

required to submit a full application on 

Form ID. To assist Commission staff in 

determining whether applicants seeking 

to obtain control of existing EDGAR 

accounts are legitimate, we will require 

such applicants to submit a new Form 

ID. To facilitate the application process, 

certain publicly available corporate and 

contact information (such as the filer’s 

name, ‘‘doing business as’’ name, 

foreign name, mailing and business 

addresses, State/country of 

incorporation, and fiscal year end) will 

be automatically prepopulated from 

EDGAR so that applicants will not need 

to resubmit that information, although 

applicants could update that 

information on Form ID as necessary.187

(7) Requiring those seeking access to 

an existing EDGAR account to upload to 

EDGAR the documents that establish the 

applicant’s authority over the company 

or individual listed in EDGAR on the 

existing account.188

In addition, we will make certain 

conforming, formatting, and ancillary 

changes to modernize Form ID without 

significantly altering the information 

required to be reported on the form. For 

example, a checkbox will be added to 

each address field for identification of 

non-U.S. locations, which will improve 

data analytics. As another example, 

company applicants will be required to 

provide their primary website address, 

if any, to provide staff additional 

contact and other information regarding 

the filer. Further, certain warnings that 

are currently listed in the EDGAR Filer 

Manual and the landing page of the 

EDGAR Filing website will be 

incorporated into Form ID to more 

clearly provide notice of those matters 

to filers.189 Additionally, as a technical 

change to what was proposed, language 

in amended Form ID and the amended 

Instructions to Form ID that advises 


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190The proposed Instructions to Form ID stated 

that filers should select ‘‘none’’ for State of 

incorporation and ‘‘N/A’’ for fiscal year end if they 

had ‘‘not yet incorporated.’’ In contrast, the 

amended Instructions to Form ID provide that filers 

should select ‘‘none’’ for State of incorporation and 

‘‘N/A’’ for fiscal year end if they had ‘‘not 

incorporated.’’ 

191For example, language in Part 6 of the 

Instructions will be revised to replace ‘‘Authorized 

Person’’ with ‘‘Authorized Individual,’’ and to 

conform with the usage of the term ‘‘authorized 

individual’’ elsewhere in the form. 

192See DFIN Comment Letter (‘‘A checkbox 

included in the Form ID to indicate a rush service 

and provide guidance for what filing scenarios 

could prompt a rush process may be beneficial.’’). 

193See Toppan Merrill Comment Letter (‘‘It may 

be helpful for filers who have an urgent need to 

complete a filing to input the date they anticipate 

needing EDGAR codes to file. This may allow the 

SEC to prioritize the applications more 

effectively.’’). 

194See Block Transfer Comment Letter (‘‘There 

ought to exist more reasonable documentation as to 

how an individual without access to EDGAR Next 

or their old EDGAR Next dashboard email might 

modify their email without imposing the undue 

burden of submitting a new Form ID (for example, 

because of a change of domain name).’’). 

195See Toppan Merrill Comment Letter (‘‘The 

Form ID process should be streamlined, technically. 

Currently the EDGAR Next Beta system requires the 

user to upload power of attorney documents and 

then print the application. After which, users must 

exit the application before uploading the signed 

authentication document. We recommend 

streamlining the process so that all the steps are 

intuitive and built into the process.’’). 

196See Toppan Merrill Comment Letter (‘‘Remove 

hyperlinks when creating the PDF. When the PDF 

is printed and electronically signed, the hyperlinks 

cause the filing to fail validation upload.’’). 

applicants not to provide unsolicited 

personally identifiable information will 

be updated to refer to attachments as 

well, and to provide examples including 

birth certificates, driver’s licenses, and 

passports. Similarly, as a technical 

change from the proposal, amended 

Form ID and the amended Instructions 

to Form ID will remind applicants not 

to name specific individuals or include 

personally identifiable information in 

the filer’s mailing address or contact 

information unless the applicant would 

like that information to become publicly 

available. In addition, as a technical 

change from the proposal, the amended 

Instructions to Form ID will be revised 

to avoid implying that companies must 

become incorporated to apply for 

EDGAR access (since, for example, 

EDGAR filers could include 

unincorporated trusts).190 Further, as a 

technical change from the proposal, 

instructions for existing applicants that 

are broker-dealers or ‘‘paper filers’’ 

seeking to electronically file on EDGAR 

will be clarified to indicate that this 

option is intended to capture applicants 

that are seeking electronic access for the 

first time. In addition, as a technical 

change from the proposal, certain 

language in Form ID that provided 

examples related to authorized 

individuals and individuals with 

individual account credentials will be 

revised to more generally express those 

concepts.191 Finally, as a technical 

change from the proposal, language in 

Form ID that instructs filers to upload 

a Form ID authenticating document 

along with their Form ID submission 

will be revised to clarify that the upload 

should be in PDF format. 

Two commenters suggested that we 

amend Form ID to permit applicants to 

indicate that they have an urgent 

upcoming filing deadline. One 

specifically requested that a checkbox 

be included in Form ID to indicate a 

rush service, and that we provide 

guidance for which filing scenarios 

could prompt a rush process.192 The 

other recommended that filers be able to 

input the date they anticipate needing 

EDGAR codes in order to submit a 

filing, thereby allowing the SEC to 

prioritize applications more 

effectively.193 While we acknowledge 

the commenters’ requests, we believe 

that allowing filers with pending filing 

deadlines to ‘‘skip the queue’’ for Form 

ID processing would encourage filers to 

delay preparing for their filing and 

increase Form ID processing times for 

other filers that timely submit their 

EDGAR access applications. As noted 

above, we are revising the note to Rule 

10 to clarify that the Commission staff 

carefully review each Form ID 

application and that filers should expect 

that the Commission staff will require 

sufficient time to review the Form ID 

upon its submission. Therefore, filers 

should submit EDGAR access 

applications on Form ID ‘‘well in 

advance’’ of their first required filing. 

Another commenter suggested there 

should be a mechanism for an 

individual to modify her email 

information without imposing the 

undue burden of submitting a new Form 

ID.194 Filers will be able to continue to 

update their EDGAR POC information, 

including email address on file, as they 

currently do, by submitting a 

COUPDAT, until the compliance date or 

the filer enrolls in EDGAR Next, 

whichever comes first. Beginning March 

24, 2025, filers that enroll must make all 

updates to their EDGAR POC on the 

dashboard by updating the EDGAR POC 

account administrator information or 

changing the account administrator 

designated as the EDGAR POC. Filers 

that have not enrolled will be able to 

submit a COUPDAT to update EDGAR 

POC information until September 12, 

2025. Beginning September 15, 2025, all 

filers must make updates to their 

EDGAR POC information on the 

dashboard. 

A commenter asked that the Form ID 

application process be streamlined, 

asserting that the process of printing 

and uploading documents was not 

intuitive, based on its experience in the 

beta environment that was provided 

during the comment period to allow 

commenters to test the EDGAR Next 

functionality discussed in the Proposing 

Release (‘‘Proposing Beta’’).195 The 

Proposing Beta required applicants to 

complete Form ID online, including 

attaching any additional documentation 

required by Part 5 of proposed Form ID, 

inputting their name and title in the 

signature page in Part 6 of proposed 

Form ID, and then returning to Part 5 of 

proposed Form ID to print the 

completed electronic form (or save it as 

a PDF). The printed form (or PDF) 

would then be manually (or 

electronically) signed by the applicant 

and notarized to serve as the proposed 

Form ID authenticating document. This 

authenticating document would then be 

uploaded and submitted in Part 5 of 

proposed Form ID. We will continue to 

require the Form ID authenticating 

document, which we believe is a helpful 

means to verify the identity of the 

applicant. However, to address the 

commenter’s concern, we will change 

the order of Parts 5 and 6 in Form ID, 

so that applicants will be able to 

complete Parts 1–5 of the form and then 

will only need to attach, print (or save 

as a PDF), and upload documents in 

Part 6 (as opposed to going back and 

forth between Parts 5 and 6 as in the 

Proposing Beta). 

The commenter also asked that 

hyperlinks included in Form ID be 

suppressed when the Form ID 

authenticating document is created, on 

the grounds that those hyperlinks cause 

Form ID authenticating documents that 

were saved as PDFs to fail EDGAR 

validation when those PDFs are 

uploaded to EDGAR.196 As discussed 

above, we will implement this 

suggestion. 

Collectively, the final amendments to 

Form ID will enhance the security of 

EDGAR by allowing Commission staff to 

obtain more information about the 

applicant and its contacts. This, in turn, 

will help staff to confirm the identity of 

the applicant and the individuals 

associated with the applicant, assess 

whether the application is properly 

authorized, and determine whether 

there are any other issues relevant to the 

application for EDGAR access for staff’s 

consideration. 


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197See Rule 301 of Regulation S–T. 198See generally section II.A. 199 Id.187. 200 Id.188. 201See generally section II.E.2. 

202See, e.g., SCG Comment Letter (urging the 

Commission to consider a third round of beta 

testing for the EDGAR Next platform, and to 

conduct additional outreach during the enrollment 

period to educate market participants). Cf. DFIN II 

Comment Letter (supporting a third beta testing 

session before the Commission finalizes the 

rulemaking so that testing allows for end-to-end 

processing through filing.); ICI Comment Letter 

(same). 

G. EDGAR Filer Manual Changes 

As discussed throughout this release, 

the Commission is amending Volume I 

of the EDGAR Filer Manual in accord 

with the rule and form amendments. 

The Filer Manual contains information 

needed for filers to make submissions 

on EDGAR. Filers must comply with the 

applicable provisions of the Filer 

Manual in order to assure the timely 

acceptance and processing of filings 

made in electronic format.197 Filers 

must consult the Filer Manual in 

conjunction with our rules governing 

mandated electronic filings when 

preparing documents for electronic 

submission. 

Amendments to Volume I of the 

EDGAR Filer Manual are being made to 

reflect the EDGAR Next changes, 

including the following in particular: 

(1) The requirement that each 

applicant or filer may only authorize to 

act on its behalf on EDGAR those 

individuals who have obtained 

individual account credentials, and 

instructions regarding how those 

individuals must obtain those 

individual account credentials through 

Login.gov; 198

(2) The requirement to submit a new 

Form ID for an existing filer seeking 

EDGAR access if the filer indicates it 

has: (i) lost electronic access to its 

existing CIK account because, for 

example, the filer failed timely to 

perform annual confirmation or (ii) is 

the legal successor of the filer named on 

the existing CIK account but did not 

receive access from that filer; 199

(3) The requirement for applicants 

seeking access to an existing EDGAR 

account to upload to EDGAR the 

documents that establish the applicant’s 

authority over the company or 

individual listed in EDGAR on the 

existing account; 200 and 

(4) Instructions regarding filer API 

tokens and user API tokens, including 

information on when these tokens will 

be required and how they will be 

used.201

Along with the adoption of the 

amendments to Volume I of the Filer 

Manual, we are amending Rule 301 of 

Regulation S–T to provide for the 

incorporation by reference into the Code 

of Federal Regulations of the current 

revisions. This incorporation by 

reference was approved by the Director 

of the Federal Register in accordance 

with 5 U.S.C. 552(a) and 1 CFR part 51. 

The updated EDGAR Filer Manual, 

issued September 27, 2024, is available 

at https://www.sec.gov/edgar/ 

filerinformation/current-edgar-filermanual. 

In addition, prior to the compliance 

date for all other rule and form 

amendments on September 15, 2025, the 

Commission expects to adopt additional 

changes to Volume II of the EDGAR 

Filer Manual in accord with the rule 

and form amendments. These changes 

will be addressed in a separate release. 

H. Transition Process 

Compliance with EDGAR Next will be 

required 12 months from the issuance of 

this release. An initial six-month 

preparation period for the EDGAR Next 

changes will begin September 30, 2024 

and extend until March 21, 2025, as 

requested by several commenters. On 

March 24, 2025, the EDGAR Filer 

Management dashboard will go live and 

compliance with the amended Form ID, 

which must be submitted through the 

dashboard, will be required. In addition, 

beginning March 24, 2025, filers may 

begin to enroll on the dashboard and 

connect to optional EDGAR APIs if they 

wish to do so, while still being able to 

file pursuant to the legacy filing process. 

Legacy filing on the EDGAR filing 

websites will continue until September 

12, 2025. Compliance with all rule and 

form changes is required on September 

15, 2025. Filers may continue to enroll 

after the compliance period for another 

three months, until December 19, 2025. 

Beginning December 22, 2025, filers that 

have not enrolled in EDGAR Next or 

received access through submission of 

amended Form ID will be required to 

submit amended Form ID to request 

access to their existing accounts. 

The transition period is consistent 

with certain commenters’ 

recommendations, which suggested that 

filers would need preparation time of 

approximately six months and 

enrollment time of approximately six 

months, as detailed in further detail 

below. We are offering preparation time 

of six months, enrollment prior to 

compliance of six months, and 

enrollment after compliance of three 

months. We address commenters’ 

feedback on the transition period in the 

compliance section below. 

An Adopting Beta will be available 

shortly after the issuance of this release 

and will remain open throughout the 

transition period until at least December 

19, 2025. We believe this Adopting Beta 

will help filers to test the EDGAR Next 

functionality and will also bring 

awareness to the public regarding the 

forthcoming changes. Commenters were 

broadly in favor of additional beta 

testing and for additional public 

outreach regarding the EDGAR Next 

changes, as discussed below.202

The following graphic illustrates the 

transition period to EDGAR Next: 


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106198 Federal Register / Vol. 89, No. 248 / Friday, December 27, 2024 / Rules and Regulations 

From Monday, September 30, 2024 to 

Friday, March 21, 2025, filers will be 

afforded a preparation period of 

approximately six months during which 

they may test in the Adopting Beta and 

conduct related development, including 

but not limited to connection to beta 

versions of all APIs to be offered as part 

of EDGAR Next. In addition, individuals 

that filers intend to authorize to act on 

their behalf may obtain Login.gov 

individual account credentials. Further, 

filers may assemble information they 

will need to enroll in EDGAR Next, 

including but not limited to ensuring 

that they possess their current 

passphrase and determining whom they 

will authorize as account 

administrators. 

On Monday, March 24, 2025, the new 

EDGAR Filer Management website 

including the dashboard will go live, 

enrollment of existing filers will 

commence, and applicants for EDGAR 

access will be required to comply with 

the amended Form ID. Existing filers 

will enroll on the dashboard. 

Prospective new filers and other filers 

that are unable to enroll must complete 

and submit amended Form ID on the 

dashboard. Individuals will need 

Login.gov individual account 

credentials to log into the dashboard. 

A person authorized by the filer will 

log into the dashboard to enroll the filer. 

On the dashboard, the person 

authorized by the filer will enter the 

filer’s CIK, CCC, and passphrase, as well 

as the names of and relevant 

information about the individuals the 

filer is authorizing as its account 

administrators. If the information is 

accurate, enrollment could be effective 

the same day submitted. Enrolled filers 

will be able to make submissions 

through the optional APIs if they 

otherwise satisfy the requirements to 

connect to the APIs, while still being 

able to file pursuant to the legacy filing 

process. Submissions on the legacy 

EDGAR filing websites (EDGAR Online 

Forms and EDGAR Filing) will continue 

to be made using the legacy EDGAR 


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203See supra note 208. 

204Existing filers may need to submit a new Form 

ID in the following situations: (i) the filer is a 

broker-dealer or ‘‘paper filer’’ seeking electronic 

access for the first time in order to file 

electronically on EDGAR; (ii) the filer lost 

electronic access to its existing CIK account; or (iii) 

the applicant is a legal successor of the filer named 

on the existing CIK account but did not receive 

access from that filer. 

access codes until September 12, 2025, 

according to the same process currently 

in place. The period during which the 

legacy filing process is available after 

enrollment begins is being set at six 

months to minimize the period during 

which confusion may arise due to 

simultaneous EDGAR operations in both 

the EDGAR Next and the legacy EDGAR 

frameworks. 

In addition, on March 24, 2025, 

compliance will be required with 

amended Form ID. On that date, 

prospective new filers and existing 

EDGAR filers that are unable to enroll 

must apply for EDGAR access on the 

amended Form ID. They will do so by 

logging into the dashboard on the new 

EDGAR Filer Management website with 

Login.gov individual account 

credentials, navigating to Apply for 

Access, and completing the 

requirements of the form. Those 

required to apply for EDGAR access on 

amended Form ID include both 

prospective filers seeking access to 

EDGAR for the first time and existing 

filers that must apply for access to 

EDGAR because they: (i) lost electronic 

access to their existing EDGAR account; 

(ii) are a legal successor of the filer 

named on the existing EDGAR account 

but did not receive access from that 

filer; or (iii) are a broker-dealer or 

‘‘paper filer’’ seeking electronic access 

for the first time in order to file 

electronically on an existing EDGAR 

account in their name. If Commission 

staff grant the amended Form ID 

application, the filer will be in 

compliance with the EDGAR Next 

changes, and thus will not be required 

to subsequently enroll on the 

dashboard. 

The EDGAR filing websites will 

continue to employ the current 

submission process for all filers until 

Friday, September 12, 2025. On 

Monday, September 15, 2025, the 

compliance date, all EDGAR websites 

will require filers’ compliance with the 

EDGAR Next rule and form changes in 

order to make submissions, including 

but not limited to Login.gov individual 

account credentials and authorization 

through the dashboard. 

On September 15, 2025, the 

compliance date, EDGAR will require 

individual account credentials on the 

EDGAR filing websites (as well as the 

EDGAR Filer Management website). At 

that time, individuals who seek to make 

submissions and take other actions for 

filers on EDGAR will be required to 

enter Login.gov individual account 

credentials and be authorized to access 

EDGAR through enrollment, on 

amended Form ID, or on the dashboard. 

After the compliance date, until 

December 19, 2025, filers who have not 

yet enrolled will not be able to make 

submissions or take other actions in 

EDGAR other than enroll on the EDGAR 

Filer Management dashboard. The 

enrollment process will remain the 

same as prior to the compliance date— 

requiring the filer to provide their CIK, 

CCC, passphrase, and names and 

information about authorized account 

administrators. If filers do not possess 

their CCC or passphrase, methods will 

be available for them to reset those 

codes in order to enroll.203 After 

December 19, 2025, filers who have not 

enrolled in EDGAR Next will be 

required to submit the amended Form 

ID on the dashboard to apply for access 

to their existing EDGAR accounts. 

The detailed transition timeline is as 

follows: 

September 30, 2024—Prepare for 

EDGAR Next changes 

Æ Adopting Beta will open. 

Æ Adopting Beta will reflect the new 

EDGAR Filer Management website and 

the dashboard including all dashboard 

functionality discussed in this release. 

Testers can submit a ‘‘test’’ amended 

Form ID to establish fictional testing 

accounts. 

Æ Adopting Beta will contain beta 

versions of all optional APIs that will be 

available in March 2025: Submission, 

submission status, EDGAR operational 

status, filing credentials verification, 

view individuals, add individuals, 

remove individuals, change role, send 

delegation invitations, request 

delegation invitations, view delegations, 

view filer account information, create 

custom CCC, generate CCC, and EDGAR 

Next enrollment. 

Æ The Overview of EDGAR APIs and 

API Toolkit will be available to filers. 

Æ Adopting Beta will reflect the 

current versions of the two legacy 

EDGAR filing websites with the current 

submission process, because filers 

making submissions on the two legacy 

EDGAR filing websites (EDGAR Online 

Forms and EDGAR Filing) between 

March 24, 2025 and September 12, 

2025, will do so according to current 

EDGAR processes. 

March 24, 2025—Enrollment of existing 

filers begins; application for access on 

amended Form ID required for 

prospective new filers and filers unable 

to enroll 

Æ New EDGAR Filer Management 

website including the dashboard will go 

live and will require Login.gov 

individual account credentials for login. 

Æ Amended Form ID will be required. 

D New applicants seeking access to 

EDGAR must submit the amended Form 

ID through the dashboard on the new 

EDGAR Filer Management website. 

D Existing filers required to submit 

Form ID must submit the amended 

Form ID through the dashboard on the 

new EDGAR Filer Management 

website.204

D If Commission staff grant the 

amended Form ID application, the filer 

will be in compliance with the EDGAR 

Next changes, and thus will not be 

required to subsequently enroll on the 

dashboard. 

Æ Enrollment for EDGAR Next will 

begin. 

Æ All APIs provided in the Adopting 

Beta will go live and be available to 

filers enrolled in EDGAR Next and filers 

whose amended Form ID applications 

have been granted by Commission staff. 

Æ Filers will make submissions on the 

legacy EDGAR filing websites using the 

current EDGAR process until September 

12, 2025. 

Æ ABSCOMP submissions will be 

made through the dashboard, as 

opposed to through the ‘‘Retrieve/Edit 

Data’’ section of the EDGAR Filing 

website as is currently the case. Because 

new serial companies requested to be 

created via the ABSCOMP process will 

automatically inherit all dashboard 

information (e.g., contact information, 

account administrators, users, technical 

administrators, and delegations) 

associated with the ABS issuing entity 

that made the ABSCOMP submission, 

an ABS issuing entity will need to 

enroll in EDGAR Next to populate its 

information in the dashboard before 

making an ABSCOMP submission. 

Existing serial companies can be 

enrolled in EDGAR Next at any time up 

until the compliance date just as any 

other filer, since their enrollment will 

not affect the ability of the ABS issuing 

entity to make an ABSCOMP 

submission. 

Æ The Adopting Beta will continue to 

be available and will be updated to 

reflect new versions of the EDGAR filing 

websites to enable filers to prepare for 

compliance with EDGAR Next on 

September 15, 2025, as discussed 

further below. 

September 15, 2025—Compliance with 

all EDGAR Next rule and form 

amendments required; enrollment 

continues 


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106200 Federal Register / Vol. 89, No. 248 / Friday, December 27, 2024 / Rules and Regulations 

205See DFIN II Comment Letter (‘‘We believe that, 

in connection with the final rule, the SEC should 

create a new role, ‘Trusted Filer’. . . . By 

grandfathering in existing Filing Agents and their 

filing activity, this would establish a baseline of 

existing EDGAR filers.’’); ICI Comment Letter 

(‘‘Grandfathering existing filing agents and their 

filing activity would establish a baseline of existing 

EDGAR filers.’’). 

206 Individual and single-member company filers 

do not need to themselves enroll in EDGAR Next, 

although they may do so if they choose. As with 

other filers, individual or single-member company 

filers may authorize a representative to enroll them, 

so long as they provide that representative with the 

necessary codes and account administrator 

information. The representative authorized to enroll 

the filer need not be an ‘‘authorized individual’’ as 

that term is defined in amended Rule 11 and 

Volume I of the EDGAR Filer Manual. 

207See supra text accompanying note 36. 

208Filers that have lost or forgotten their CCC will 

be able to reset it by providing their CIK and 

passphrase and using the ‘‘Generate New EDGAR 

Access Codes’’ option in the Filer Management 

website until March 21, 2025. Similarly, filers that 

have lost or forgotten their passphrase will be able 

to reset it by selecting the ‘‘Update Passphrase’’ 

option on the EDGAR Filer Management website to 

send a security token to the email associated with 

the account until March 21, 2025, and, until that 

date, if the POC email address is not current, filers 

can first submit a COUPDAT to update the email 

address associated with the account. Filers that 

have lost or forgotten their passphrase, no longer 

have access to the email associated with the 

account, and cannot submit a COUPDAT through 

the ‘‘Retrieve/Edit Data’’ section of the EDGAR 

Filing website to update the email associated with 

the account, must reapply for EDGAR access on 

Form ID. We encourage filers that have lost or 

forgotten their access codes to reset their credentials 

on or before March 21, 2025, to avoid delay in 

enrollment. The current ‘‘Generate New EDGAR 

Access Codes’’ and ‘‘Update Passphrase’’ options 

will no longer be available on the EDGAR Filer 

Management website after that website is updated 

on March 24, 2025. From March 24, 2025 through 

December 19, 2025, filers will be able to update 

their passphrase on the dashboard by selecting 

‘‘Enroll in EDGAR Next,’’ following the prompts to 

request a passphrase reset token and resetting the 

passphrase. The email address associated with the 

account must be current to use the dashboard 

passphrase reset process, and filers would similarly 

need to update the email address in EDGAR before 

using this process should the email address on file 

be inaccessible. The ability to reset the CCC will 

also be provided to filers during this time. 

209See, e.g., DFIN Comment Letter (‘‘We think 

those credentials are sufficient. However, Filing 

Agents do not typically ask for or retain the 

passphrases. Unless the EDGAR contact in the 

company information is able to use the security 

token process to obtain a new passphrase, the 

manual process of obtaining a new passphrase is 

time consuming.’’); Workiva Comment Letter 

(‘‘Passphrases are used to reset accounts, and they 

are likely infrequently used. Many administrators 

Æ Access to all EDGAR websites— 

EDGAR Online Forms, EDGAR Filing, 

and EDGAR Filer Management—will 

require Login.gov individual account 

credentials. 

Æ Filers must comply with all 

requirements of Rule 10 and the EDGAR 

Filer Manual to make submissions on 

EDGAR. 

Æ The Adopting Beta will continue to 

be available until at least December 19, 

2025. 

Æ Because individual account 

credentials will be required to access all 

EDGAR websites, legacy EDGAR access 

codes (password, passphrase, and 

PMAC) will no longer be used to access 

EDGAR. (Filers who seek to enroll 

between September 15, 2025 and 

December 19, 2025, however, must enter 

a CCC and a passphrase to do so, 

therefore, the ability to reset the CCC 

and the passphrase will remain 

available.). 

Æ Filers may continue to enroll after 

the compliance date, until December 19, 

2025. 

December 19, 2025—Enrollment ends 

Æ Enrollment ends on December 19, 

2025. 

December 22, 2025—Application on 

amended Form ID required for all 

existing and prospective filers seeking 

access to EDGAR 

Æ Existing filers that have not 

enrolled or otherwise no longer have 

access and all prospective filers must 

apply for access to EDGAR on amended 

Form ID on the dashboard beginning 

December 22, 2025. 

1. Enrollment Process 

Existing filers will enroll in EDGAR 

Next through the dashboard on the new 

EDGAR Filer Management website and 

will not be required to submit a Form 

ID. The enrollment section of the 

dashboard will provide two options: (i) 

manual enrollment of single EDGAR 

accounts on an account-by-account 

basis; and (ii) enrollment of multiple 

accounts simultaneously. In addition, as 

discussed in section II.E.1.b.v, an 

enrollment API will be provided to help 

streamline the enrollment process. 

Although the enrollment API will be 

available to all filers, we expect it will 

generally be used by filing agents, 

service providers, or corporate affiliates 

that will manually enroll themselves 

earlier in the transition period and then 

connect to the enrollment API to enroll 

their clients and affiliated entities. 

Two commenters appeared to suggest 

that enrollment should occur 

automatically without filer involvement, 

so that filing agents would be 

automatically authorized as account 

administrators and delegated entities for 

any CIK for which the filing agent had 

previously made a submission.205 We 

decline to adopt the commenters’ 

suggestion. To enroll, an individual 

authorized by the filer to perform 

enrollment on its behalf must enter the 

file’s CIK, CCC and passphrase, as well 

as information about the individuals 

being authorized as account 

administrators.206 The entry of account 

administrator information during 

enrollment represents the filer’s 

affirmative authorization of account 

administrators, who play a key role in 

the EDGAR Next framework as the 

individuals who manage the filer’s 

account. Further, if the filer determined 

to authorize individuals employed at 

the filer or at a different filing agent as 

its account administrators due to 

business needs, personal preference, or 

whatever other reason, a process of 

affirmative enrollment ensures that the 

filer indeed intends to authorize those 

individuals to manage its account. 

a. Preparing for Enrollment—Individual 

Account Credentials 

Individuals may obtain individual 

account credentials from Login.gov in 

advance of enrollment. Individuals with 

existing Login.gov credentials based 

upon a personal email address may 

create separate Login.gov credentials for 

EDGAR based upon a different email 

address that they will use in connection 

with EDGAR.207

As a result, when enrollment begins, 

filers will be able to immediately enroll 

any individuals who have obtained 

individual account credentials. 

b. Manual Enrollment for a Single 

EDGAR Account 

As a preliminary matter, each filer 

will be required to authorize at least two 

individuals to manage the filer’s EDGAR 

account as account administrators, with 

the exception of individuals and singlemember companies, which will be 

required to authorize at least one 

account administrator. On behalf of 

each filer, an individual authorized to 

enroll the filer will enter her individual 

account credentials to log into the 

dashboard to enroll. That individual 

will manually enter the filer’s CIK, CCC, 

and EDGAR passphrase,208 to confirm to 

EDGAR that the individual is authorized 

by the filer. If EDGAR authenticates that 

data, the individual authorized to enroll 

the filer will proceed to enter account 

administrator names, contact 

information, and the email addresses 

each individual used to obtain Login.gov 

individual account credentials. By 

entering that information, the filer will 

indicate its authorization of the listed 

individuals as the filer’s account 

administrators, as well as the accuracy 

of the information provided. 

Commenters generally agreed that 

CIK, CCC, and EDGAR passphrase 

would be sufficient to authenticate filers 

for transition purposes, but noted that 

filing agents typically do not retain 

filers’ passphrases and expressed 

concerns regarding burdens associated 

with obtaining filers’ passphrases.209


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and individual reporting owners may not know the 

passphrase or how to obtain it . . . If the 

passphrase must be required, the Commission may 

want to consider a process for inactive entities to 

refresh their passphrase.’’). 

210 If a filer cannot reset its passphrase by 

following this guidance, it may submit a manual 

passphrase update request. To do so, an authorized 

individual of the filer must submit a signed and 

notarized document to Commission staff that 

includes an explanation of why the request is being 

made, the CIK of the EDGAR account to which 

access is sought, the filer name on the account, and 

the contact information of the requesting entity 

purporting to have current control over the filer 

associated with the account. Commission staff may 

request the applicant to submit additional 

documents for staff review. Filers submitting 

manual passphrase update requests should expect 

that Commission staff may need a substantial 

amount of time to review their requests, especially 

if a large volume of requests is received. As 

discussed above, the manual passphrase update 

option available via ‘‘Update Passphrase’’ will no 

longer be available on the EDGAR Filer 

Management website after that website is updated 

on March 24, 2025. Instead, from March 24, 2025 

through December 19, 2025, filers will be able to 

update their passphrase on the dashboard. See 

supra note 208. 

211See, e.g., Workiva Comment Letter (‘‘A 

sweeping change of CCCs should especially be 

avoided as it could pose a significant burden and 

risks to the filing process. Filers concerned about 

the CCC could choose to change it themselves. A 

filer led approach puts the security responsibility 

and control in the filer’s hand to ensure the CCC 

update happens at a time that does not put their 

immediate filings at risk.’’); Toppan Merrill 

Comment Letter (‘‘It would be unnecessary to reset 

the CCC upon enrollment. If bulk enrollment is 

utilized it would most likely be completed by an 

entity [. . .] that already has access to the filer’s 

CCC. It would be burdensome for the filer if the 

CCC is automatically changed as they would need 

to communicate the updated CCC to those that 

should have access.’’); ICI Comment Letter (‘‘Bulk 

enrollment should be permitted without reset CCCs 

upon re-enrollment.’’). 

212See DFIN Comment Letter (‘‘We agree that 

notification of a completed enrollment should be 

provided to all account administrators.’’). 

213See supra section II.E.1.b.i (discussing the 

filing credentials verification API) and section 

II.E.1.b.iv (discussing the view filer account 

information API). 

214See DFIN Comment Letter (‘‘We agree that 

notification of a completed enrollment should be 

provided to all account administrators.’’). 

215See Workiva Comment Letter (‘‘We support 

auto-notification to the POC about the enrollment 

if the POC is not also enrolled as an administrator 

. . .’’). 

216See Toppan Merrill Comment Letter 

(‘‘Currently, there is no alert to the previous/ 

existing EDGAR Contact when the EDGAR Contact 

email address is updated. We do not believe it is 

necessary to alert the current EDGAR POC during 

the transition to EDGAR Next. It is possible that 

many of the EDGAR POCs will have been recently 

updated to reset the passphrase as part of the 

EDGAR Next transition. Therefore, this alert would 

go to the person who completed the EDGAR Next 

transition and may be redundant.’’). 

While we acknowledge that many filing 

agents do not know the passphrases of 

their filers and some filers have 

forgotten and may need to reset their 

passphrases, we believe that provision 

of the filer’s passphrase is critical to 

authenticating a filer and confirming the 

filer’s intent to enroll. Filers that have 

lost or forgotten their passphrase may 

automatically reset their passphrase by 

requesting a security token be sent to 

their POC email address on record in 

EDGAR, consistent with current 

practice. Filers that have lost or 

forgotten their passphrase and that no 

longer have access to the POC email 

associated with the account should 

update their POC email address on 

record by making a COUPDAT 

submission via the ‘‘Retrieve/Edit Data’’ 

section of the EDGAR Filing website. 

The staff will provide filers step-by-step 

instructions on the EDGAR Next page 

on SEC.gov when the Adopting Beta 

opens regarding how to automatically 

reset their passphrase, as well as how to 

update their POC email address on 

record. We anticipate that filers 

following these instructions should be 

able to reset their passphrase relatively 

quickly.210

We requested comment on whether a 

filer’s CCC should be automatically reset 

as a security measure following 

enrollment. Commenters generally 

opposed this measure on the grounds 

that it would impose burdens on filers 

to communicate the updated CCC to 

those that should have access and could 

impose burdens and risks to the filing 

process.211 Separately, one commenter 

stated that if the Commission decides to 

change a filer’s CCC after enrollment 

then similar precautions should also be 

taken regarding the passphrase.212

Although we are sensitive to the 

concerns raised by commenters that 

resetting the filer’s CCC after enrollment 

could be burdensome, we balance those 

concerns with our efforts to protect the 

security of EDGAR. Just as with 

someone’s personal password, security 

is improved by frequently changing 

access codes. Changing the CCC is 

particularly important in the context of 

enrollment because the code could be 

shared insecurely when preparing to 

enroll. Further, for filers that have not 

reset their CCC for some period of time, 

changing the CCC upon enrollment 

represents a clean start, and assures that 

someone who possesses the legacy CCC 

but is not authorized by the filer at or 

after enrollment could not continue to 

make submissions for the filer from 

March 24, 2025 to September 12, 2025, 

when legacy filing codes will continue 

to be used to make web-based 

submissions. Moreover, the presence of 

the CCC on the dashboard after it is 

reset will ensure that it is available for 

all individuals that the filer is currently 

authorizing to take action on its 

account. Accordingly, following a filer’s 

enrollment in EDGAR Next, the filer’s 

CCC will be automatically reset. To 

minimize burdens associated with 

communicating the new CCC to relevant 

individuals, however, the new CCC will 

appear on the dashboard for all 

individuals with the ability to make 

submissions on the filer’s behalf (i.e., 

account administrators, users, delegated 

administrators, and delegated users). In 

addition, APIs will be offered to view 

filer account information, including 

CCC, and verify filing credentials, 

including CCC. Collectively, these APIs 

should minimize burdens associated 

with notifying relevant individuals 

regarding changes to a filer’s CCC, both 

in the enrollment context and as a 

general matter.213

Separately, on the compliance date of 

September 15, 2025, legacy EDGAR 

access codes will be deactivated, 

including the passphrase, password and 

PMAC, because the filer will no longer 

have any need for these codes. For 

example, the passphrase is used to 

authenticate the generation of access 

codes such as CCC and password, but 

after enrollment, use of the passphrase 

and password will be discontinued, and 

filers will generate the CCC on the 

dashboard. The EDGAR Next framework 

of individual account credentials, 

account administrator dashboard 

invitation, and CCC will supplant these 

codes. 

Successful enrollment will result in 

notifications being provided to all 

newly authorized account 

administrators, as recommended by a 

commenter.214 These notifications will 

be sent both by email and through the 

dashboard, consistent with all other 

notifications to individuals who are 

authorized on the dashboard. One 

commenter suggested that the existing 

EDGAR POC should also be notified in 

the event of a successful enrollment.215

Another commenter noted that currently 

no notification is provided to the 

previous EDGAR POC when the contact 

email address is updated, and asserted 

that such a notification would be 

redundant to the extent it would be 

going to the same person who enrolled 

the filer and who listed herself as the 

filer’s account administrator.216 After 

considering these comments, EDGAR 

will be enhanced to notify the existing 

EDGAR POC in the event of a successful 

enrollment. Although in some cases this 

will result in redundant notifications (if 

the existing EDGAR POC is one of the 

new account administrators being 

authorized during enrollment), sending 

uniform notifications to all existing 


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217See Workiva Comment Letter (‘‘We believe 

that confirmation from the current POC should not 

be required. When a POC was set up a long time 

ago, there may have been turnover, and the contact 

information may not be up to date even with an 

email on file. The administrators also may not know 

who their POCs are. POC confirmation should not 

be required because this is a mandatory transition 

and missing or outdated POC could be a prohibiting 

factor and a serious risk of chaos for the enrollment 

process.’’). 

218See supra note 209 and accompanying text. 

219See Toppan Merrill Comment Letter (‘‘Yes, 

bulk enrollment should be permitted as planned.’’); 

DFIN Comment Letter (‘‘We agree that the 

limitation of 100 is acceptable for bulk 

enrollment.’’); ICI Comment Letter (‘‘Bulk 

enrollment should be permitted. . ..’’); XBRL II 

Comment Letter (‘‘We agree with the proposed 

approach to allow bulk enrollment of multiple 

EDGAR accounts. We recommend that the CSV 

limit be increased to 500, from the proposed limit 

of 100.’’). 

220See supra note 214 and accompanying and 

following text. 

221See supra note 215 and accompanying and 

following text. 

222See supra note 211 and accompanying and 

following text. 

223See Workiva Comment Letter (‘‘Moreover, we 

recommend extending the transition period to 

twelve months to allow time for process and system 

changes.’’). 

224See Workiva Comment Letter (‘‘With the above 

considerations, we suggest three months from final 

rule adoption to start enrollment instead of one 

month.’’) (‘‘However, we strongly believe that six 

months is not adequate for the full transition. Filers 

need to do more than enrolling to completely 

transition. They have to modify their processes 

based on the new EDGAR Next requirements and 

the filing software that they use. Likewise, filing 

agents and software providers do not only have to 

enroll their own users and ensure all delegations 

are properly set up (which again could be in the 

tens of thousands), they also need to learn about the 

final rule, provide information and instructions to 

their filers, do software development, roll out 

changes to their filers, potentially with a beta 

process of their own.’’). 

EDGAR POCs will provide clarity to 

filers. 

We will not require the existing 

EDGAR POC to consent to the filer’s 

enrollment. As mentioned by one 

commenter, the filer’s EDGAR POC on 

record may not be current, and missing 

or outdated EDGAR POCs could cause 

confusion and delays in the enrollment 

process.217 Separately, we believe that 

requiring CIK, CCC, and passphrase will 

be sufficient to authenticate filers for 

transition purposes, as discussed above 

and as supported by commenters.218

Each EDGAR account will enroll 

once. If there is an attempt to enroll an 

EDGAR account that is already enrolled, 

the subsequent attempted enrollment 

will be denied. An individual filer who 

makes submissions related to multiple 

companies (e.g., the CEO of one 

company who is also on the board of 

directors of other companies) may have 

more than one filing agent and/or 

representative at such companies who 

have access to her CIK, CCC, and 

EDGAR passphrase. Accordingly, an 

individual filer should authorize one 

representative to enroll her EDGAR 

account and determine whom she will 

authorize as her initial account 

administrator(s) during enrollment. 

After enrollment, the authorized 

account administrator(s) would 

communicate with the filer’s other filing 

agents and/or company representatives 

and add such other filing agents and/or 

company representatives to the filer’s 

account as account administrators, 

users, or delegated entities through the 

dashboard. Any individuals to be 

authorized on the filer’s account will be 

required to possess individual account 

credentials. 

c. Bulk Enrollment of Multiple EDGAR 

Accounts 

Simultaneous bulk enrollment of 

multiple EDGAR accounts, together 

with those filers’ account 

administrators, will be available. This 

process should prove efficient and time 

saving for filing agents, as well as 

individuals and entities that control 

multiple EDGAR accounts, such as 

serial companies created by ABS issuing 

entities or investment companies under 

the control of a single investment 

adviser. 

To begin bulk enrollment, an 

individual authorized to enroll the 

relevant filer accounts will log in to an 

enrollment page on EDGAR with his 

individual account credentials. The 

individual will complete and upload a 

spreadsheet accommodating multiple 

rows of data, with each row pertaining 

to a single filer. The individual will 

enter data for each filer on each row, 

including CIK, CCC, and EDGAR 

passphrase to ensure that enrollment is 

being performed by a properly 

authenticated individual. In addition, 

the individual will enter on each row 

information regarding the filer’s 

prospective account administrators, 

including names, contact information, 

and the email addresses associated with 

the individual account credentials of the 

account administrators, to indicate that 

the filer authorizes those account 

administrators to manage its EDGAR 

account. The bulk enrollment process 

will allow a filer to list two account 

administrators. Although all filers are 

encouraged to list two account 

administrators for bulk enrollment 

purposes, single-member companies 

and individuals who self-identify as 

such will be permitted to list only one 

account administrator. There will be a 

limit of 100 filers (100 rows) per bulk 

enrollment. Commenters generally 

supported the bulk enrollment option as 

contemplated in the Proposing Release, 

including the limitation of 100 filers per 

spreadsheet, although one commenter 

suggested that the limit per spreadsheet 

be increased to 500 filers.219 There will 

be a limit of 100 rows per spreadsheet 

as it appears that number is sufficient 

for most filers. Filers that wish to 

submit bulk enrollment requests on 

behalf of more than 100 CIKs may 

engage in multiple, separate bulk 

enrollments. 

As discussed above, each successful 

enrollment will result in notifications to 

all newly authorized account 

administrators, as recommended by a 

commenter.220 In addition, EDGAR will 

be enhanced to notify the existing 

EDGAR POC in the event of a successful 

notification.221 Following a filer’s 

enrollment in EDGAR Next, EDGAR will 

automatically reset the filer’s CCC and 

deactivate the filer’s passphrase for 

security reasons.222 Also as discussed 

above, enrollment will only occur once 

per EDGAR account, and each filer 

should carefully coordinate with its staff 

and other representatives to determine 

the person to be authorized to enroll the 

filer and the persons to be authorized as 

account administrators during the 

enrollment. Authorized account 

administrators may thereafter manage 

the account (e.g., adding additional 

account administrators, users and 

technical administrators) on the 

dashboard. 

2. Compliance 

Compliance with the final 

amendments and transition to EDGAR 

Next will be required on September 15, 

2025, 12 months after the issuance of 

this adopting release. Filers may begin 

to enroll on March 24, 2025, six months 

prior to the compliance date. Filers will 

be able to enroll until December 19, 

2025, three months after the compliance 

date. 

Commenters requested varied periods 

of time to prepare, enroll and transition 

to EDGAR Next. One commenter 

recommended a transition period of 12 

months.223 The commenter requested 

three months prior to the enrollment 

period within which to prepare for 

enrollment, noting that filers need to do 

more than enrolling to complete 

transition, including but not limited to 

creating and modifying software and 

processes, studying the rule, and 

providing information and instructions 

to filers.224 The commenter further 

stated that according to its customer 

survey a majority of respondents 

indicated that six months would be an 


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225See Workiva Comment Letter (‘‘Based on the 

enrollment activities described in the proposed 

rule, we believe that six months is adequate to 

enroll. According to our customer survey, over 53% 

of respondents indicated that six months work fine, 

provided that it is after the annual filing season.’’). 

226See DFIN II Comment Letter (‘‘DFIN is 

reinforcing our responses to Question 59 [of DFIN 

I Comment Letter], a nine-month enrollment period, 

as numerous registrants are not participating in the 

Beta.’’) and DFIN I Comment Letter (‘‘If filers are 

allowed six months after the proposed rule goes 

final and before enrollment, we agree that the 

compliance timeline is sufficient. If the six-month 

period before enrollment is not met, we suggest a 

nine-month enrollment period.’’). 

227 XBRL II Comment Letter (‘‘We recommend a 

12-month transition period for filers to enroll their 

EDGAR accounts into EDGAR Next.’’). 

228See SCG Comment Letter (requesting a 12- 

month enrollment period, with an additional six 

months for section 16 filers to transition). 

229See ICI Comment Letter (‘‘ICI recommends a 

minimum of nine months for implementation given 

the complexity and number of Fund filings. The 

outreach and coordination necessary for Funds to 

appropriately delegate filing authority to their filing 

agents makes an extended transition period for bulk 

EDGAR filers vital. The proposed transition period 

would give these bulk filers only one month to 

establish processes and procedures for using 

EDGAR Next.’’). 

230See DFIN II Comment Letter; Workiva 

Comment Letter; ICI Comment Letter. 

231See DFIN II Comment Letter; Workiva 

Comment Letter; ICI Comment Letter. 

232See SCG Comment Letter (requesting an 

additional six months for section 16 filers to 

transition). 

233Of 208,000 active EDGAR accounts (those in 

which a filing has been made in the past two years), 

approximately 140,000 represent entity filers and 

approximately 68,000 represent individual filers. In 

total, regardless of account activity, there are 

approximately 1,000,000 filer accounts in EDGAR, 

however, we believe that most of the approximately 

800,000 inactive EDGAR filer accounts are defunct 

and therefore would not transition to EDGAR Next. 

adequate amount of time to enroll 

provided that it occurred after annual 

filing season.225 A second commenter 

requested a minimum of nine months to 

transition to EDGAR Next, and 

indicated that filers would need six 

months to enroll if they were afforded 

six months after adoption to prepare for 

enrollment.226 A third commenter 

recommended a 12-month transition 

period for filers to enroll. 227 A fourth 

commenter agreed with a 12-month 

transition period for filers to enroll, but 

requested an additional six months for 

section 16 filers to enroll.228 A fifth 

commenter recommended a minimum 

of nine months for implementation, and 

suggested that it would require adequate 

time in advance of enrollment to 

establish processes and procedures for 

EDGAR Next.229

We have considered these comments 

and noted that several commenters 

expressed a need for adequate time after 

adoption to prepare for enrollment.230

As a result, we determined to 

significantly extend the time for filers to 

prepare for enrollment from one month 

as proposed to six months as adopted, 

which aligns with the recommendation 

of those commenters.231 During this 

time, the beta environment will be 

available to filers to test the EDGAR 

Next changes, prepare their systems and 

develop any necessary software. In 

addition, filers will be able to ensure 

they have all the information needed to 

enroll, such as their CIK, CCC, and 

passphrase (and will have time to reset 

their passphrase if necessary). Filers 

will have time to determine whom they 

will authorize as account administrators 

and make arrangements with potential 

delegated entities and individuals, as 

well as to execute relevant notarized 

powers of attorney if needed. Filing 

agents will have an opportunity to 

communicate with their current client 

filers about enrollment. Section 16 filers 

may determine how they wish to 

authorize management of their EDGAR 

account. Filers may further test the 

enrollment process in the beta 

environment and be fully prepared to 

enroll at the end of the six-month 

preparation period. 

We believe that the 12-month 

transition process, including a sixmonth preparation period and a sixmonth enrollment period, that we are 

providing is consistent with 

commenters’ recommendations. As 

noted above, filers will have six months 

to conduct preparations and testing 

prior to the beginning of enrollment. 

When enrollment commences, 

individuals whom filers have 

authorized to perform enrollment 

should be prepared to log into the new 

dashboard with individual account 

credentials they have obtained from 

Login.gov and to enter filers’ CIK, CCC, 

and passphrase, as well as information 

to authorize account administrators to 

enroll on the dashboard. Filers will have 

six months within which to enroll prior 

to the compliance date. Once enrolled, 

account administrators can delegate 

authority to file and otherwise set up 

filers’ accounts on the dashboard. Once 

authorized by account administrators, 

technical administrators can generate 

filer API tokens for filers connecting to 

APIs, and filers can begin to connect to 

those APIs to make submissions and 

otherwise communicate with EDGAR. 

One commenter requested an 

additional six months for section 16 

filers to transition to EDGAR Next.232

We believe that the additional three 

months after the compliance date for 

enrollment that we are offering should 

assist periodic filers, such as section 16 

filers, to enroll in EDGAR Next and 

meet their filing obligations if they do 

not enroll prior to the compliance date. 

Further, we believe that the transition 

period affords sufficient time for section 

16 and other filers to prepare for EDGAR 

Next and enroll prior to the compliance 

date. The staff plans to provide 

information to section 16 filers through 

the EDGAR Next page on SEC.gov and 

other communications. 

A bulk enrollment option will allow 

enrollment of multiple filers 

simultaneously. In addition, as 

discussed above, an enrollment API will 

be available to streamline enrollment. 

As soon as filers enroll in EDGAR Next, 

they will be able to connect to all 

available APIs. We believe that filers 

will be incentivized to enroll by the 

availability of APIs upon enrollment, 

and they will have had time to develop 

connections and test those APIs. The 

Adopting Beta will be available 

throughout the transition period until at 

least December 19, 2025. We believe the 

transition period will provide sufficient 

time for filers to prepare and enroll in 

EDGAR Next, while maintaining 

security and efficiency for filers and 

EDGAR operation.233

To assist filers in their transition to 

EDGAR Next, Commission staff will 

begin public outreach immediately after 

the issuance of this release. Staff will 

publicize the transition to EDGAR Next 

and link to additional information in 

announcements and email distributions, 

SEC social media, and the homepage of 

SEC.gov. Commission staff also will 

provide multiple resources on a 

dedicated EDGAR Next web page to 

assist with the transition, including but 

not limited to, written step-by-step 

guidance for testing a range of 

functionality in the Adopting Beta 

environment and information about staff 

webinars and API technical help 

sessions for the public. On the SEC 

YouTube channel, staff will post videos 

to walk filers through various aspects of 

the EDGAR Next changes. To assist 

filers with any issues that may arise, 

Commission staff will provide dedicated 

telephone support and an email help 

desk—EDGARNextBeta@sec.gov—as 

well as an online form (available in the 

Adopting Beta) to report technical bugs. 

III. Other Matters 

If any of the provisions of these rules, 

or the application thereof to any person 

or circumstance, is held to be invalid, 

such invalidity shall not affect other 

provisions or application of such 

provisions to other persons or 

circumstances that can be given effect 

without the invalid provision or 

application. 


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234See EDGAR Filer Manual, Volume I, at section 

4. For a discussion of the functions of these access 

codes, please see the ‘‘Understand and utilize 

EDGAR CIKs, passphrases, and access codes’’ 

section of the ‘‘EDGAR—How Do I’’ FAQs, at 

https://www.sec.gov/edgar/filer-information/howdo-i. 

235See EDGAR Filer Management, available at 

https://www.filermanagement.edgarfiling.sec.gov; 

EDGAR Filing, available at https://

www.edgarfiling.sec.gov/Welcome/ 

EDGARLogin.htm; and EDGAR Online Forms, 

available at https://www.edgarfiling.sec.gov/ 

Welcome/EDGAROnlineFormsLogin.htm. 

236Section 2(b) of the Securities Act (15 U.S.C. 

77b(b)), section 3(f) of the Exchange Act (17 U.S.C. 

78c(f)) and section 2(c) of the Investment Company 

Act (15 U.S.C. 80a–2(c)) require the Commission, 

when engaging in rulemaking where it is required 

to consider or determine whether an action is 

necessary or appropriate in (or, with respect to the 

Investment Company Act, consistent with) the 

public interest, to consider, in addition to the 

protection of investors, whether the action will 

promote efficiency, competition, and capital 

formation. Further, section 23(a)(2) of the Exchange 

Act (17 U.S.C. 78w(a)(2)) requires the Commission, 

when making rules under the Exchange Act, to 

consider the impact that the rules will have on 

competition, and prohibits the Commission from 

adopting any rule that would impose a burden on 

competition not necessary or appropriate in 

furtherance of the purposes of the Exchange Act. 

The technological changes contemplated by EDGAR 

Next will work together with the final rule and form 

amendments to enhance EDGAR access 

requirements. Because it is difficult to isolate the 

economic effects associated with the technological 

changes from those attributable solely to the final 

rule and form amendments, for purposes of this 

economic analysis, we have considered these effects 

collectively. 

237See 15 U.S.C. 78p. 

238This number includes 63,676 applications 

from prospective filers without CIKs, 9,602 

applications from filers that had lost EDGAR access 

and were seeking to regain access to EDGAR 

(currently submitted as passphrase updates, but 

pursuant to EDGAR Next will be submitted on Form 

ID), and 322 applications from filers with CIKs who 

had not yet filed electronically on EDGAR. 

239Similarly, this number includes applications 

from prospective filers without CIKs, applications 

from filers that had lost EDGAR access and were 

seeking to regain access to EDGAR (currently 

submitted as passphrase updates, but pursuant to 

EDGAR Next will be submitted on Form ID), and 

applications from filers with CIKs who had not yet 

filed electronically on EDGAR. 

240See supra note 12. 

241See Regulation S–T, Rule 10; EDGAR Filer 

Manual, Volume I. 

Pursuant to the Congressional Review 

Act, the Office of Information and 

Regulatory Affairs has designated these 

rules as a ‘‘major rule,’’ as defined by 5 

U.S.C. 804(2). 

IV. Economic Analysis 

Individuals and entities submit filings 

electronically with the Commission 

through EDGAR in order to comply with 

various provisions of the Federal 

securities laws. While EDGAR has 

provided an effective means for 

individuals and entities to satisfy their 

electronic filing obligations, there are 

limitations to the current system. 

EDGAR does not currently track a filing 

to the specific individual who made it. 

EDGAR access is currently governed by 

a complex combination of several codes 

with differing functions.234 In addition, 

the Commission is aware that some 

filers may have failed to maintain secure 

access to their EDGAR accounts.235

EDGAR Next will improve the ability 

of filers to securely manage and 

maintain access to their EDGAR 

accounts and simplify procedures for 

accessing EDGAR by modernizing the 

mechanism by which filers and 

individuals they authorize act on filers’ 

behalf on EDGAR and streamlining the 

management of filers’ accounts in 

EDGAR. Various technical features and 

optional APIs will also be integrated 

into EDGAR to facilitate communication 

with EDGAR, thus enhancing filing 

efficiency and providing automation for 

filers that wish to connect to the 

optional APIs. EDGAR Next will benefit 

both filers and the Commission by 

simplifying procedures for accessing 

EDGAR and identifying the specific 

individuals submitting filings, thereby 

facilitating the responsible management 

of filer credentials and enhancing the 

security of EDGAR. Enhancing the 

security of EDGAR will better protect 

against unauthorized access to the 

system, thereby decreasing the 

likelihood of unauthorized filings that 

might result in economic costs for the 

public, filers, and the Commission. 

The discussion below addresses the 

potential benefits and costs that may 

result from the final rule and form 

amendments the Commission is 

adopting in this release, and certain 

related technical changes, as well as the 

likely effects of EDGAR Next on 

efficiency, competition, and capital 

formation.236 We also discuss the 

potential economic effects of certain 

alternatives to the approaches taken in 

this release. Where possible, we have 

attempted to quantify the benefits, costs, 

and effects on efficiency, competition, 

and capital formation expected to result 

from the final amendments. In many 

cases, however, the Commission is 

unable to quantify certain economic 

effects because it lacks the information 

necessary to provide estimates or 

ranges. In those circumstances where 

we do not have the requisite data to 

assess the quantitative impact of the 

EDGAR Next changes, we have analyzed 

their economic impact qualitatively. 

A. Baseline 

Our baseline includes the current 

requirements to obtain access to and file 

on the Commission’s EDGAR system, as 

well as the account management 

practices as they exist today. The main 

parties directly affected by EDGAR Next 

are current and prospective filers as 

well as relevant individuals or entities 

acting on the filers’ behalf. Filers are 

individuals or entities (e.g., public 

operating companies, investment 

companies, broker-dealers, transfer 

agents, and other institutions that have 

filing obligations with the Commission) 

that make a submission electronically 

through EDGAR. For example, 

beneficial ownership reporting filers 

(such as individual filers who are 

officers and/or directors with reporting 

obligations under section 16 of the 

Exchange Act) routinely rely upon the 

companies for which they serve to make 

filings on their behalf on EDGAR.237

Other filers may make filings on behalf 

of affiliated or related entities, such as 

investment companies on behalf of 

other companies in their fund family or 

asset-backed securities issuers on behalf 

of the serial companies they create. In 

2023, the Commission received 

approximately 73,600 Form ID 

submissions.238 From 2018 to 2023, an 

average of approximately 63,984 Form 

IDs were submitted per year to the 

Commission.239

Individuals and entities that seek to 

file on EDGAR must apply for access in 

accordance with Rule 10 of Regulation 

S–T by completing the Form ID 

application online. Applicants must 

then print a copy of the completed form. 

An authorized individual, as defined in 

the EDGAR Filer Manual, Volume I, 

must sign the completed form, and this 

signature must be notarized, pursuant to 

the EDGAR Filer Manual, Volume I. 

Filers have the flexibility to obtain 

notarization of the authorized 

individual’s signature on Form ID 

through manual, electronic, or remote 

online notarization in accord with 

Volume I of the EDGAR Filer Manual 

and Rule 10 of Regulation S–T.240 The 

signed, notarized copy of the completed 

Form ID is the Form ID authenticating 

document, and the applicant must 

upload that document for Commission 

staff review.241 Form ID currently 

collects information including but not 

limited to the applicant’s contact 

information and EDGAR POC. If the 

application is granted by Commission 

staff, the filer receives a unique CIK, and 

the EDGAR POC generates access codes, 

including but not limited to a password 

and a CCC, by using its CIK and 

passphrase. These codes allow the filer 

to make submissions on its EDGAR 

account. The current co-registrant filing 

process does not require the 


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242See EDGAR Filer Manual, Volume I, at section 

4(b). 

243See EDGAR Filer Manual, Volume I, at section 

5 (‘‘Filers must maintain accurate company 

information on EDGAR, including but not limited 

to a filer’s current name, business mailing address, 

and business email address.’’); see also EDGAR 

Filer Manual, Volume I, at section 4 (‘‘Filers must 

securely maintain all EDGAR access codes and limit 

the number of persons who possess the codes. 

EDGAR access codes include the password, 

passphrase, CCC, and password modification 

authorization code (PMAC).’’). 

244See Staff Guidance for EDGAR Filing for 

Asset-Backed Securities Issuers, available at https:// 

www.sec.gov/divisions/corpfin/abs092418.pdf. This 

guidance represents the views of Commission staff. 

It is not a rule, regulation, or statement of the 

Commission. The Commission has neither 

approved nor disapproved its content. Staff 

statements have no legal force or effect: they do not 

alter or amend applicable law, and they create no 

new or additional obligations for any person. 

245See EDGAR Filer Manual, Volume I, at section 

4 (‘‘Filers must securely maintain all EDGAR access 

codes and limit the number of persons who possess 

the codes.’’). 

246See supra note 233. 

247See EDGAR Filer Management website 

available at https://

www.filermanagement.edgarfiling.sec.gov; EDGAR 

Filing website available at https://

www.edgarfiling.sec.gov/Welcome/ 

EDGARLogin.htm; and EDGAR Online Forms 

website available at https://

www.edgarfiling.sec.gov/Welcome/ 

EDGAROnlineFormsLogin.htm. 

248See CompSci Resources Comment Letter 

(November 19, 2021); Workiva Comment Letter 

(November 30, 2021). 

249Applicants will, among other things: (1) 

designate on Form ID specific individuals that the 

filer authorizes to take action on its behalf as 

account administrator(s); (2) provide the applicant’s 

Continued 

presentation of a password for all 

entities. 

If a filer loses or must update its 

passphrase, it can request that a security 

token be sent to the POC email address 

on record with EDGAR. If necessary, the 

filer can first update the POC email 

address to ensure it receives the security 

token. If, for some reason, a filer is 

unable to update its passphrase via a 

security token, a manual passphrase 

update request must be submitted.242 In 

conjunction with a manual passphrase 

update request, the authorized 

individual must submit a signed and 

notarized document to Commission staff 

that includes an explanation of why the 

request is being made, the CIK of the 

EDGAR account to which access is 

sought, the filer name on the account, 

and the contact information of the 

requesting entity purporting to have 

current control over the filer associated 

with the account. Depending upon the 

circumstances of the access request, 

additional documents may need to be 

submitted to Commission staff for 

review. For example, additional 

documents would need to be provided 

when the applicant indicates it has 

assumed control of the entity on the 

EDGAR account so that Commission 

staff can establish whether a legal 

transition from the filer on the account 

to the applicant occurred. 

EDGAR filers are subject to certain 

requirements set forth in the EDGAR 

Filer Manual, according to which they 

must: (1) renew their EDGAR password 

annually; (2) maintain accurate 

company information on EDGAR; and 

(3) securely maintain EDGAR access 

codes.243 Filers can update their POC 

information, including email address on 

file, by submitting a COUPDAT via the 

Retrieve/Edit Company Submission 

Data tab on the EDGAR filing website. 

Filers can similarly submit a SCUPDAT 

or ABSCOMP using the Retrieve/Edit 

Company Submission Data tab. Filers 

can submit up to 100 ABS issuing 

entities in a single submission.244

Currently, access to EDGAR does not 

incorporate individual account 

credentials or multifactor 

authentication. Commission staff have 

no systematic way to determine with 

whom the filer has shared EDGAR 

access codes, or when the filer has 

revoked an individual’s authorization to 

file. Filers are responsible for 

safeguarding their access codes and 

limiting the number of individuals who 

receive the codes.245 Certain filers and 

filing agents currently devise their own 

internal systems to track who possesses 

their EDGAR access codes. Because the 

Commission does not collect the 

personal information of the specific 

individual who makes the submission, 

nor does the Commission issue 

identifying credentials to individuals 

acting on behalf of filers, it is currently 

difficult for Commission staff to match 

filings to specific individuals who made 

the filings. 

EDGAR receives a large volume of 

filings, typically more than 500,000 per 

calendar year, and has approximately 

208,000 active filers, of which 

approximately 140,000 represent 

entities and approximately 68,000 

represent individuals.246 Filers make 

submissions on EDGAR through one of 

three web-based user interfaces, 

depending on the type of submission 

made.247

The majority of EDGAR filings are 

made by filing agents on behalf of their 

client filers.248 Certain filing agents and 

filers use proprietary custom software to 

interface with EDGAR to eliminate the 

need for human web-based interaction 

with the EDGAR filing websites. To 

create this custom software, these filing 

agents and filers extract data from the 

EDGAR filing websites and then 

configure their custom software to 

mimic a web-based interaction. This 

mode of interaction with EDGAR 

requires frequent maintenance of the 

custom software; however, since 

whenever EDGAR filing websites 

change their content or structure, those 

changes impact the custom software. 

Although Commission staff do not 

provide technical or other support for 

custom software interaction with 

EDGAR, staff seeks to minimize filing 

disruptions and strives to provide notice 

to filers prior to making website 

changes. As a result, technical changes 

to the EDGAR system (e.g., 

maintenance, updates, etc.) may be 

slowed by the fact that staff is mindful 

of the downstream effect of such 

technical changes on the custom 

software used by filing agents and filers. 

B. Consideration of Benefits and Costs 

as Well as the Effects on Efficiency, 

Competition, and Capital Formation 

1. Benefits 

EDGAR Next is designed to: provide 

a more secure framework for filers to 

manage and maintain access to their 

EDGAR accounts; facilitate the 

responsible management of filer 

credentials; and simplify procedures for 

accessing EDGAR. We anticipate the 

main economic benefits of the final 

amendments will be to enhance the 

security of EDGAR by reducing the risks 

of unauthorized access to filers’ 

accounts and unauthorized filings. 

Reducing these risks will in turn 

mitigate the adverse economic 

consequences, such as financial harms, 

to filers and market participants that 

could result from unauthorized access 

and filings. EDGAR Next will also 

streamline the management of filer 

credentials and accounts, simplify 

procedures to access EDGAR, and allow 

for a more automated filing process and 

preparation. This may result in cost 

savings for some filers and delegated 

filers and help enhance the 

Commission’s regulatory oversight 

through greater prevention and timely 

detection of unauthorized access and 

filings. We discuss below the benefits of 

specific provisions of EDGAR Next. 

a. Form ID 

As discussed in section II.F.3, Form 

ID as adopted, will include changes to 

information required to be reported on 

the form as well as technical changes. 

Individuals, companies, and other 

organizations that seek access to file 

electronically on EDGAR, or to establish 

or re-establish their electronic access to 

an existing account, will be required to 

submit Form ID as amended.249 The 


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LEI, if any; (3) provide more specific contact 

information about the filer and the filer’s account 

administrator(s), authorized individual, and billing 

contact; (4) specify whether the applicant, its 

authorized individual, person signing a power of 

attorney, account administrator, or billing contact 

has been criminally convicted or civilly or 

administratively enjoined barred, suspended, or 

banned in any capacity as a result of a Federal or 

State securities law violation; (5) indicate whether 

the company seeking access is in good standing 

with its State or country of incorporation; and (6) 

require those seeking access to an existing EDGAR 

account to upload documents establishing their 

authority over the account. 

250The EDGAR Filer Manual will provide 

guidance regarding what documents are sufficient 

to establish the applicant’s authority. See amended 

EDGAR Filer Manual, Volume I, at section 3. 

251See supra note 31. 

252See, e.g., Workiva Comment Letter (stating that 

individuals may share their individual account 

credentials among various employees at the 

delegated entity); XBRL II Comment Letter (noting 

that multifactor authentication is ‘‘only required to 

administer the Filer Management dashboard and 

obtain [] filer and user tokens which could leave the 

system vulnerable to a malicious entity’’ that 

somehow obtained the filer’s filer API token and 

user API token from using those tokens for 30 days). 

253See amended EDGAR Filer Manual, Volume I, 

at section 3(a). 

final amendments to Form ID will 

enhance the security of EDGAR and 

benefit EDGAR users by providing 

additional identity assurances that 

individuals taking actions on EDGAR on 

behalf of the filer are authorized to do 

so, thus minimizing the risk of 

unauthorized access to filers’ EDGAR 

accounts. For instance, if the applicant 

authorizes a prospective account 

administrator who is not employed by 

the applicant or its affiliate, amended 

Form ID requires a notarized power of 

attorney from the applicant to authorize 

the designated individual to be its 

account administrator. In the case of 

certain applicants who seek to reestablish access to an existing account, 

the amended Form ID requires an 

applicant to upload to EDGAR the 

documents establishing the applicant’s 

authority over the account, consistent 

with current requirements.250 The 

provision of more specific contact 

information about the filer, the filer’s 

account administrator(s), authorized 

individual, and billing contact will 

allow Commission staff to reach the 

filer’s account administrators, 

authorized individual, and billing 

contacts when necessary, which will 

benefit the filer and the Commission by 

facilitating a swift resolution to 

potential issues that may affect their 

accounts. 

b. Individual Account Credentials 

As discussed in section II.B.1, 

paragraph (d)(1) of Rule 10 as adopted, 

will require that all existing and 

prospective filers authorize individuals 

on the dashboard to act on their behalf 

only if those individuals have obtained 

individual account credentials. The 

EDGAR Filer Manual, Volume I is being 

amended to specify that individual 

account credentials be obtained through 

Login.gov, a U.S. agency site that 

employs multifactor authentication. 

Paragraph (d)(1) of Rule 10 as proposed 

and adopted will generally improve the 

security of the EDGAR system by: 

eliminating the use of multiple EDGAR 

access codes and the sharing of them 

with others in an unsecure manner 

outside of the EDGAR system; 

associating a filing with the relevant 

individual who submitted the filing 

(due to the person-specific nature of 

individual account credentials); and 

providing an additional layer of 

validation with multifactor 

authentication. Improving the security 

of EDGAR will generally minimize the 

risk of unauthorized access to filers’ 

accounts as well as unauthorized filings, 

thereby also minimizing any resulting 

adverse economic consequences, such 

as market manipulation or financial 

harm to a company or its investors. For 

instance, unauthorized filings can lead 

to the release of false information about 

a public company, which could 

negatively impact its investors, 

investors’ trust in the company, and the 

company’s access to capital markets. 

Some commenters agreed that the 

individual account credential 

requirements will improve security, 

promote individual accountability, and 

adhere to current best practices.251

Other commenters questioned the 

benefit of paragraph (d)(1) of Rule 10, 

asserting that individual account 

credentials could intentionally be 

shared with unauthorized persons.252

The EDGAR Filer Manual is being 

amended to clarify that individual 

account credentials may not be shared 

with other individuals as individual 

account credentials are intended to 

identify the individual taking action on 

EDGAR.253 To the extent that authorized 

persons nonetheless inadvertently share 

their individual account credentials, 

this could limit the benefits described 

above. Because we anticipate that such 

instances will be rare, we believe that 

requiring individual account credentials 

will meaningfully enhance the overall 

security of the EDGAR system. 

c. Account Administrators 

As discussed in section II.B.1, 

amended paragraph (d)(2) of Rule 10 

will require filers to authorize account 

administrators to act on the filers’ behalf 

to manage their accounts on the 

dashboard. The addition of account 

administrators will help ensure that 

filers’ accounts are secure by preventing 

unauthorized access, thereby reducing 

the risk of security incidents and the 

resulting financial harms. Account 

administrators will be able to authorize, 

view, and de-authorize the individuals 

and delegated entities on the dashboard 

as warranted. Requiring filers to 

authorize account administrators will 

enhance security and improve filer 

compliance with EDGAR Next 

requirements by facilitating the 

prevention and timely detection of 

potential economic harms resulting 

from unauthorized access. For example, 

account administrators will oversee the 

filer’s EDGAR account and can 

promptly revoke access for users who 

are no longer authorized by the filer. 

Moreover, by granting account 

administrators direct authority to 

oversee the filer’s account, account 

administrators can promptly address 

user access problems and correct errors 

in a timely manner, ensuring faster 

resolution of issues that may affect 

filers’ accounts. 

d. Final Amendments to Paragraphs 

(d)(4), (d)(5), and (d)(6) of Rule 10 and 

Rule 11 

As discussed in section II, the final 

amendments to paragraphs (d)(4), (d)(5), 

and (d)(6) of Rule 10 require the filer, 

through its authorized account 

administrators: to annually confirm that 

all individuals reflected on the 

dashboard for the filer’s EDGAR account 

are authorized by the filer and that all 

information regarding the filer on the 

dashboard is accurate; to maintain 

accurate and current information about 

the filer on EDGAR; and to securely 

maintain information relevant to the 

ability to access the filer’s EDGAR 

account. The final amendments will 

assist the filer in tracking and 

confirming those individuals and 

delegated entities authorized to act on 

behalf of the filer and to remove those 

no longer authorized. Confirming the 

accuracy of information about 

individuals authorized to act on behalf 

of filers while safeguarding access to 

account-related information will reduce 

the risk of unauthorized access to filers’ 

accounts and the potential for 

unauthorized filings, thereby enhancing 

the security of EDGAR. Taking measures 

that help prevent unauthorized access is 

inherently more efficient than 

remediating the consequences of such 

events after they have occurred, which 

may include damage to public 

confidence in the filings provided, with 

corresponding adverse effects for 

markets. 


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254See supra section II.E.1 for a description of the 

APIs. 

255See supra note 147. 

256See supra section II.E.1 for a description of the 

APIs. In the event that a filer connects to the 

submission status API, they will continue to receive 

EDGAR submission notifications. 

The final amendments to Rule 11 of 

Regulation S–T will define new terms 

related to EDGAR Next, update the 

definitions of certain existing terms, and 

delete outdated terminology from 

certain definitions in Rule 11. Rule 11 

also defines ‘‘dashboard’’ as an 

interactive function on EDGAR where 

filers manage their EDGAR accounts and 

where individuals that filers authorize 

may take relevant actions for filers’ 

accounts. These amendments should 

help facilitate compliance by filers and 

filing agents with the EDGAR Next filing 

requirements. 

The dedicated EDGAR dashboard will 

offer a range of benefits to filers related 

to their obligations under paragraphs 

(d)(4), (d)(5) and (d)(6) of Rule 10 in the 

form of: (1) simplified management of 

EDGAR accounts because account 

administrators can manage the filer’s 

account through a number of functions 

on the dashboard; (2) streamlined 

compliance because account 

administrators can utilize efficient 

account management functions, 

including editing filer information and 

performing the required annual 

confirmation on the dashboard; (3) 

enhanced security by allowing account 

administrators to remove individuals 

and entities no longer authorized to act 

on behalf of the filer, and requiring 

individual account credentials and 

multifactor authentication to access the 

dashboard; and (4) increased efficiency 

by providing a secure and centralized 

way to manage the filer’s EDGAR 

account, reducing the risk of human 

error in managing account information 

or compromised access codes. 

Commission staff are aware that 

certain filers and filing agents currently 

have internal systems that track which 

individuals possess their EDGAR access 

codes. While the cost to these filers of 

transitioning to the dashboard is 

expected to be the same as that for filers 

that do not have internal systems, filers 

with internal systems will benefit on an 

ongoing basis if they use the dashboard 

instead of their current system due to 

the elimination of ongoing maintenance 

costs for their internal tracking system. 

Moreover, the dashboard will offer the 

advantage of being a uniform system for 

all filers that additionally allows 

Commission staff visibility into which 

individuals are authorized to act for the 

filer, thereby enhancing regulatory 

oversight and subsequently the 

reliability of the information made 

available through EDGAR. Furthermore, 

filers without a system for tracking 

individuals in possession of EDGAR 

codes will be afforded a tool to do so 

through EDGAR, thereby facilitating 

compliance with existing EDGAR Filer 

Manual requirements and amended 

EDGAR Next obligations in Rule 10 and 

the EDGAR Filer Manual to securely 

maintain access to their accounts. 

As proposed and adopted, paragraph 

(d)(6) of Rule 10 is analogous to 

requirements set forth in the EDGAR 

Filer Manual requiring a filer to securely 

maintain its EDGAR access codes. As 

adopted, filers, through their account 

administrators, will be required to 

securely maintain information relevant 

to their ability to access their EDGAR 

accounts. Because an existing analogous 

obligation is currently set forth in the 

EDGAR Filer Manual, the benefits of 

final paragraph (d)(6) of Rule 10 are 

expected to be marginal. However, in 

the context of the adopted amendments, 

paragraph (d)(6) of Rule 10 makes clear 

that this obligation persists under 

EDGAR Next and that filers are 

responsible for meeting the obligation 

through their account administrators. 

e. Optional APIs and Technical 

Administrators 

As discussed in section II.E, EDGAR 

Next will introduce optional APIs.254

Filers may choose to connect to these 

APIs in order to facilitate the 

transmission of information to, and 

retrieval of information from, EDGAR. 

The optional APIs will particularly 

benefit larger filers with numerous users 

and CIKs by increasing filing efficiency 

and timeliness, thereby potentially 

reducing costs associated with making 

filings. In addition, the optional APIs 

aim to automate most of the functions 

of the dashboard, thereby increasing the 

efficiency of accurately managing 

EDGAR accounts for filers that use the 

optional APIs. 

The APIs will streamline the 

submission and retrieval process by 

allowing automated server-to-server 

interaction. As discussed above, many 

filing agents employ a web scraping 

process to retrieve information from 

EDGAR and create custom software that 

allows filing agents to make 

submissions on and retrieve information 

from EDGAR in an automated manner. 

Filing agents’ custom software depends 

on the underlying content and structure 

of the EDGAR web pages being scraped. 

Thus, filing agents continually incur 

costs to adjust their custom software, 

and could experience system downtime, 

because minor changes to EDGAR 

content and structure are frequently 

made, as with any major system. The 

optional APIs will provide a more 

reliable automated way for filers to 

interact with EDGAR because filers will 

not be dependent upon web scraping 

and impacted by EDGAR content and 

web page changes. This should further 

reduce the ongoing maintenance and 

personnel costs associated with custom 

software. Also, the optional APIs will 

reduce the likelihood of errors and 

inconsistencies in several ways. For 

example, the submission API will 

streamline the filing process by enabling 

filers to submit large volumes of filings 

rapidly and efficiently in an automated 

manner. This will eliminate the need to 

manually log into EDGAR and submit 

filings one by one, reducing the reliance 

on manual processes, which are more 

prone to human error.255 The 

submission status API also will allow 

filers to check the status of multiple 

submissions in a batch process. In 

addition, the submission status API will 

provide all information currently 

contained in EDGAR submission 

notifications, enabling the filer to 

engage in prompt identification and 

correction of any inconsistencies.256

As described in sections II.E.1.a.ii and 

iii, filers and filing agents, as well as 

those using third-party custom 

applications, continuously interact with 

the EDGAR system to inquire as to the 

status of submissions or the operating 

status of EDGAR. These frequent 

inquiries may generate significant 

network traffic to and from EDGAR. 

Instead of manually logging into EDGAR 

and individually checking the status of 

each submission, the submission status 

and operational status APIs will benefit 

filers by allowing them to 

simultaneously check the status of 

multiple submissions in a machine-tomachine batch process, thereby 

reducing network traffic for filers. 

Paragraph (d)(3) of Rule 10 as adopted 

requires any filer that decides to 

connect to an optional API to authorize, 

through its account administrator(s), at 

least two technical administrators to 

manage the API, unless the filer 

arranges to use its delegated entity’s 

filer API tokens and API connections so 

long as the delegated entity has 

authorized at least two technical 

administrators pursuant to paragraph 

(d)(3) of Rule 10. Filers will be allowed 

a maximum of 20 technical 

administrators to facilitate 

communication with Commission staff 

on API-related technical issues. This 

requirement will benefit filers because it 

will reduce the chance that filers’ API 

access would be interrupted for any 


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257See infra section V. 

258See supra section II.F.3. 

259See infra section V.B. 

260The $100 estimate is based on the following 

calculations: $101 (hourly rate for an operations 

specialist at $168 for 0.6 hours) ≈ $100. Salaries for 

estimates are derived from SIFMA’s Management & 

Professional Earnings in the Securities Industry 

2013, modified to account for an 1,800-hour workyear and inflation, and multiplied by 5.35 to 

account for bonuses, firm size, employee benefits 

and overhead. See infra section V.B. 

261See supra note 187. 

262Workiva Comment Letter (‘‘We believe that a 

notarized power of attorney should not be required 

to add an employee of another entity as an 

administrator. This could significantly increase the 

burden for the individual reporting owners, 

especially considering staffing changes at the 

affiliated entities. The burden could render the 

option of using an outside administrator practically 

not viable.’’). 

263Block Transfer Comment Letter (‘‘Notaries can 

pose challenges for an ever-increasing population 

with less and less access to physical bank branches 

and a distinct lack of other no-cost notarization 

providers.’’). 

unforeseen technical issues. This 

requirement will also benefit both filers 

and the Commission by providing 

Commission staff with multiple points 

of contact in case of technical issues and 

increases the likelihood that an 

individual familiar with APIs and 

related technical issues is available to 

address any difficulties that may arise. 

f. Adopting Beta and Transition Period 

The Commission will provide an 

Adopting Beta environment shortly after 

issuance of this release, which will be 

available to filers throughout the 

transition period until at least December 

19, 2025. The Adopting Beta will benefit 

filers by providing them with time and 

resources to prepare for the EDGAR 

Next changes. Filers will be able to test 

in the Adopting Beta and conduct 

related development, including but not 

limited to creation of connections to the 

optional APIs, should they choose to do 

so. Testing, identification, and 

resolution of issues in the deployment 

of a new system will benefit filers by 

reducing the risk of errors and 

minimizing disruptions to filers’ 

EDGAR operations during the transition. 

During the 12-month transition period, 

individuals that filers intend to 

authorize to act on their behalf may 

obtain Login.gov individual account 

credentials and filers may assemble 

information that they will need to enroll 

in EDGAR Next, such as their current 

CIK, CCC and passphrase, and 

information about the individuals that 

they will authorize as account 

administrators. The transition period 

will enable filers to transition to EDGAR 

Next in a planned and flexible manner, 

allowing filers to coordinate their own 

specifics onboarding needs and 

processes over the 12-month period. 

This degree of flexibility afforded to 

filers in timing their transition activities 

will facilitate compliance to EDGAR 

Next and reduce the risk of noncompliance. This is especially 

advantageous to small filers with fewer 

resources that may need more time to 

adapt to the new requirements. 

2. Costs 

The costs associated with EDGAR 

Next include one-time costs for filers 

(including filing agents) to setup their 

EDGAR dashboard, create connecting 

API internal filing applications and 

adjust any other relevant internal 

software if they opt to connect to the 

APIs.257 The costs associated with 

EDGAR Next also include ongoing costs 

for filers (including filing agents) to 

comply with new Rule 10 requirements 

related to access and management of 

EDGAR accounts. The compliance costs 

associated with EDGAR Next will vary 

depending on the size of the filer, the 

number of individuals acting on behalf 

of the filer, the filer’s existing software, 

and the complexity of a filer’s EDGAR 

application. EDGAR Next, however, 

may not increase filers’ overall net 

compliance costs since modernizing the 

EDGAR access and account management 

processes will likely reduce ongoing 

compliance costs for some activities and 

for some reporting entities, such as 

filing agents and larger filers, due to 

streamlined management of filer 

credentials and accounts, simplified 

procedures to access EDGAR, and a 

more automated process for filing on 

EDGAR and retrieval of account 

information. 

Filers that opt to interact with the 

APIs will need to create internal 

applications to connect to APIs and 

discontinue or modify their current 

usage of any custom software, but the 

one-time cost of doing these tasks will 

be mitigated by the elimination of these 

filers’ current ongoing maintenance 

costs associated with scraping EDGAR 

and adjusting custom software each 

time EDGAR undergoes changes. To 

facilitate filers’ use of the optional APIs 

and help mitigate the associated costs, 

Commission staff have developed 

technical resources to assist filers in 

creating software to connect to APIs. 

Filers will be offered a list of technical 

standards for the APIs, the expected 

inputs and outputs, and additional API 

token information. Commission staff 

will also offer an open-source code for 

a sample filing application to facilitate 

connection to the initial three APIs in 

the API Toolkit and serve as a model for 

connection to the other APIs being 

offered. 

a. Form ID 

The Commission is adopting 

amendments to Form ID requiring all 

filers seeking electronic access to 

EDGAR to submit certain additional 

information for review and approval by 

Commission staff before such access 

may be granted.258 As filers are already 

subject to the requirements of Form ID, 

the additional requirements for Form ID 

will entail certain incremental 

compliance costs.259 The Commission 

estimates that compliance costs 

associated with the new Form ID will 

increase by approximatively $100 per 

filer for each Form ID submission.260

For applicants seeking access to an 

existing EDGAR account, this cost may 

be mitigated by the fact that certain 

fields of the form will be prepopulated 

with certain publicly available 

information of the filer, which may 

reduce the cost associated with 

completing the amended form.261

One commenter argued that requiring 

a notarized power of attorney to add an 

employee of another entity as an 

account administrator could 

significantly increase the burden for 

individual reporting owners and render 

the option of using an outside account 

administrator practically not viable.262

We disagree that requiring a notarized 

power of attorney in this instance 

creates an additional cost because, as 

stated in the baseline, the EDGAR Filer 

Manual currently requires filers to 

provide a notarized power of attorney. 

Therefore, given that the power of 

attorney requirement is consistent with 

an existing requirement, we do not 

expect a material difference in cost 

compared to the baseline. 

One commenter opposed the 

notarization requirement for nonemployee account administrators 

authorized on Form ID, stating that the 

notarization may not be readily 

accessible for everyone, which might 

result in unaccounted for burdens such 

as travel time and notarization costs.263

Though we acknowledge the 

commenter’s concern, we do not believe 

these additional costs are likely to be 

significant because the notarization 

process is relatively straightforward and 

analogous to the current requirement for 

all filers to obtain the notarized 

signature of the authorized individual 

on Form ID contained in the EDGAR 

Filer Manual. Furthermore, for filers 

that may not have access to physical 

notaries, online remote notarization is 


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264See EDGAR Filer Manual, Volume I, at section 

3. The EDGAR Filer Manual specifies the 

instructions filers must follow when making 

electronic filings on EDGAR and is incorporated by 

reference in the Code of Federal Regulations by 17 

CFR 232.301 (Regulation S–T, Rule 301). Rule 10 

of Regulation S–T and the EDGAR Filer Manual 

permit manual, electronic, and remote online 

notarizations, authorized by the law of any State or 

territory of the U.S. or DC See 17 CFR 232.10 and 

EDGAR Filer Manual, Volume I, at section 3. An 

‘‘authorized individual’’ for purposes of the Form 

ID notarization process is an individual with the 

authority to legally bind an entity or individual, or 

an individual with a power of attorney from an 

individual with the authority to legally bind an 

entity or individual, as defined in Volume I of the 

EDGAR Filer Manual and Rule 11 of Regulation S– 

T. 

265See SCG Comment Letter. 

266See SCG Comment Letter. 

267See SCG Comment Letter. 

268See supra note 260. 

269See infra note 274. 

270See infra note 275. 

271 XBRL Comment Letter (‘‘[t]he economic 

[analysis] described in the proposed rule does not 

include the additional non-developmental support 

costs. Filing agents and law firms are estimated to 

be responsible for over 90% of EDGAR filings. 

Additional support costs are likely to be passed on 

to registrants.’’); Workiva Comment Letter (‘‘[t]he 

economic [ ] analysis also does not include the 

additional non-developmental support costs 

imposed on filing agents and law firms, estimated 

to be responsible for over 90% of EDGAR filings, 

which would presumably be passed on to their 

customers/registrants. The additional support and 

management burden for filing agents will be 

substantial but hard to quantify at this point.’’). 

272Workiva Comment Letter. 

273Proposing Release at 65549 (‘‘[w]e recognize 

that due to these factors, the burden incurred would 

vary across filers. Filers with a large number of 

users and significant turnover would likely spend 

a greater amount of time managing their dashboard 

accounts.’’); see also infra note 277. 

already permitted and will continue to 

be permitted by the Commission.264

b. Individual Account Credentials, 

Account Administrators 

Final paragraph (d)(1) of Rule 10 will 

require that all existing and prospective 

filers only authorize an individual to 

perform functions on the dashboard on 

their behalf if that individual possesses 

individual account credentials obtained 

through Login.gov. Requiring individual 

account credentials will impose the 

minimal step of obtaining individual 

account credentials from Login.gov in 

the EDGAR access process resulting in 

some additional time burden for 

individuals who will have an EDGAR 

role for filers. Because the use of 

individual user permissions is a 

standard practice in software 

applications and computer systems, and 

Login.gov is free to use, we do not 

believe that requiring individual 

account credentials will be unduly 

burdensome or confusing. 

One commenter stated that the 

introduction of individual account 

credentials could be disruptive and 

unduly burdensome for section 16 

filers.265 The commenter argued that 

section 16 filers will face additional 

burdens when applying for EDGAR 

access and enrolling in EDGAR Next 

themselves and requested that EDGAR 

permit a corporate secretary or legal 

personnel of a registrant to obtain 

EDGAR access for an individual section 

16 filer pursuant to a power of 

attorney.266 We acknowledge the 

commenter’s concern; however, we do 

not believe that section 16 filers will 

face additional costs beyond the costs 

that other filers incur, given the various 

compliance options available to them. 

For example, as discussed above in 

section II.B, section 16 filers with 

existing accounts may avoid obtaining 

Login.gov individual account 

credentials for EDGAR if they authorize 

an individual at their filing agent or 

other third party to enroll them in 

EDGAR Next and during enrollment 

authorize one or more individuals at 

these entities to act as their account 

administrators. Likewise, section 16 

filers who are applying for access on 

amended Form ID may use a notarized 

power of attorney to delegate to another 

person the process of obtaining 

individual account credentials and 

making filings on their behalf. The 

commenter also stated that some 

features of Login.gov (e.g., text or voice 

MFA options) are restricted in certain 

countries, which could impose an 

added burden on filers based outside 

the United States.267 As discussed in 

section II.A, Login.gov offers individuals 

several different authentication methods 

and individuals need only choose one 

method available to them. Therefore, we 

do not anticipate any additional costs 

for filers based outside of the United 

States. 

Final paragraph (d)(2) of Rule 10 will 

require filers to authorize at least two 

account administrators to act on the 

filers’ behalf to manage their accounts. 

Filers that are individuals or singlemember companies will be required to 

authorize and maintain at least one 

account administrator. Prospective 

EDGAR filers will designate on 

amended Form ID the individuals that 

the filer authorizes as account 

administrators. As such, the compliance 

costs associated with the new Form 

ID 268 reflects the burden associated 

with the enrollment of account 

administrators. Existing filers will 

authorize their account administrators 

through a function on the dashboard, 

which is encompassed in the one-time 

cost that filers will incur to set up their 

accounts on the EDGAR Next 

dashboard.269 Additionally, other costs 

associated with account administrators 

are encompassed by the costs associated 

with ongoing maintenance of the 

dashboard.270

We do not expect individual or singlemember filers to hire additional 

personnel in order to comply with final 

paragraph (d)(2) of Rule 10 because 

individual or single-member filers may 

act as their own account administrators 

or authorize an individual at their filing 

agent or other representative entity as an 

account administrator. Existing filers 

also may authorize an individual at 

their filing agent or other third party to 

enroll them in EDGAR Next and during 

enrollment authorize one or more 

individuals at these entities to act as 

their account administrators. Similarly, 

filers who apply for access on amended 

Form ID may authorize one or two 

individuals at their filing agents or 

relevant companies as their account 

administrators, so long as they execute 

a relevant notarized power of attorney. 

Nevertheless, this requirement will 

result in the opportunity cost of 

personnel being less available to attend 

to other matters while performing their 

account administrator duties. 

Two commenters asserted that the 

Proposing Release’s economic analysis 

did not sufficiently account for 

additional non-developmental support 

costs imposed on filing agents and law 

firms that may need to hire additional 

personnel to manage the administrative 

aspects of the dashboard, which likely 

will be passed on to registrants.271 One 

commenter acknowledged that the 

additional support and management 

burden for filing agents is difficult to 

quantify, which makes it hard for the 

Commission to evaluate.272 As stated in 

the Proposing Release, filers with a large 

number of users would spend a greater 

amount of time managing their 

dashboard accounts.273 We anticipate 

that most large filers and filing agents 

will authorize their own employees or 

affiliates in order to comply with final 

paragraph (d)(2) of Rule 10 and will not 

need to hire additional personnel. 

However, we acknowledge that a large 

filer or filing agent will face additional 

costs if it needs to hire additional 

personnel to comply, and we recognize 

that, although only two account 

administrators are required, a filer or 

filing agent may hire as many as 20 

account administrators. To the extent 

additional personnel need to be hired, 

there will be costs associated with the 

hiring process. 


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274The $200 estimate is based on the following 

calculations: $168 (hourly rate for an operations 

specialist at $168 for 1 hour) ≈ $200. Salaries for 

estimates are derived from SIFMA’s Management & 

Professional Earnings in the Securities Industry 

2013, modified to account for an 1,800-hour workyear and inflation, and multiplied by 5.35 to 

account for bonuses, firm size, employee benefits 

and overhead. See infra section V.C. 

275The $200 estimate is based on the following 

calculations: $168 (hourly rate for an operations 

specialist at $168 for 1 hour) ≈ $200. Salaries for 

estimates are derived from SIFMA’s Management & 

Professional Earnings in the Securities Industry 

2013, modified to account for an 1,800-hour workyear and inflation, and multiplied by 5.35 to 

account for bonuses, firm size, employee benefits 

and overhead. See infra section V.C. 

276See infra section V.C. 

277 If a filer fails to perform a timely annual 

confirmation, after a three-month grace period, it 

must complete and submit a Form ID to apply for 

access to file on EDGAR. If Commission staff grant 

the Form ID, a filer will need to re-invite any users, 

technical administrators, and additional account 

administrators to its account, and reissue delegation 

invitations, if relevant. Re-issuing invitations will 

take longer for larger filers and filing agents with 

many users acting on behalf of the filer. 

278See infra section V.C. 

279See supra notes 170 and 171. 

280Workiva Comment Letter (‘‘The annual 

confirmation requirement would increase the 

burden on all filers due to the amount of user 

content to review, and it contributes to the overall 

higher complexity for filers to manage in order to 

file.’’). 

281See supra section II.B.1. 

282These notices will be provided in the 

dashboard and also be sent via email to all account 

administrators’ email addresses (e.g., the 

confirmation deadline notices will be periodically 

provided in both email and via the dashboard 

multiple times leading up to the deadline to ensure 

that the account administrators are fully aware of 

the pending deadlines). See supra section II.1 

(discussing account administrators). 

283See supra section II.E.2. 

284 Delegated account administrators cannot 

perform annual confirmation for the filer. 

285Single member companies and individuals are 

only required to authorize and maintain at least one 

account administrator. 

286 XBRL Comment Letter (‘‘The annual 

confirmation requirement will create a significant 

additional burden for filers that use a filing agent’s 

SEC credentials, in particular for those filers who 

make sporadic submissions such as Section 16 

filers.’’). See also Toppan Merrill Comment Letter 

(‘‘This update particularly impacts Section 16 filers 

who do not frequently file or rely on the Issuer to 

submit their filings.’’). 

c. Final Amendments to Paragraphs 

(d)(4), (d)(5), and (d)(6) of Rule 10, and 

Rule 11 

As adopted, paragraph (d)(4) of Rule 

10 will require each filer through its 

account administrators to perform an 

annual confirmation on EDGAR that all 

account administrators, users, technical 

administrators, and delegated entities 

reflected on its dashboard are 

authorized by the filer to act on its 

behalf and that all information about the 

filer on the dashboard is accurate. The 

annual confirmation requirement will 

impose additional compliance costs on 

filers to review the accuracy of their 

EDGAR account information on the 

dashboard. We estimate that, in the first 

year, there will be a one-time cost of 

approximatively $200 per filer, on 

average, to set-up the filer’s account on 

the EDGAR Next dashboard.274 We also 

estimate that, there will be a recurring 

cost, including in the first year, of 

approximatively $200 per filer, on 

average, to manage the filer’s 

dashboard.275 These costs will likely 

vary with the number of users that the 

filer authorizes and the amount of 

turnover of relevant personnel.276 For 

example, a filer with a large number of 

users that experiences high turnover in 

users could have to spend more time 

managing its dashboard, in which 

instance it will incur additional costs to 

do so.277 Filing agents are also likely to 

face higher dashboard management 

costs if they authorize a large number of 

individuals and have multiple accepted 

delegations and user groups for which 

delegated users will need to be 

maintained.278 Such costs will likely be 

mitigated by active notifications and 

other efficiencies provided by the 

dashboard, and the optional APIs as an 

account management tool. 

We have sought to ease the transition 

to EDGAR Next for filers by allowing 

enrollment of multiple accounts 

simultaneously on the dashboard, via 

bulk enrollment of up to 100 filers and 

their account administrators. The bulk 

enrollment feature will particularly 

benefit large filing agents enrolling 

multiple accounts by saving time and 

labor costs, which will help mitigate 

against any higher compliance costs 

these entities would otherwise incur. 

We are also offering an optional API to 

facilitate the enrollment process and 

lower costs. 

As adopted, paragraphs (d)(5) and 

(d)(6) of Rule 10 are analogous to 

existing requirements set forth in the 

EDGAR Filer Manual, and filers are not 

expected to incur significant 

incremental costs of compliance given 

they should already be complying with 

these requirements when using the 

EDGAR system.279 We also do not 

expect filers to incur compliance costs 

related to the new terms defined in 

amended Rule 11. 

One commenter said that proposed 

paragraph (d)(4) of Rule 10 contributes 

to an overall higher complexity for filing 

agents with a large number of accounts 

and associated individuals due to the 

sheer amount of information required to 

review.280 The provision of multiple 

notices of the impending confirmation 

deadline to account administrators via 

email and dashboard notifications,281 as 

well as the three-month grace period 

provided after the confirmation 

deadline has passed before deactivation 

occurs,282 will help ensure that the 

filer’s account administrators receive 

adequate notice and opportunity to 

timely perform confirmation without 

negatively affecting their submission 

preparation lead time. This will help 

minimize the administrative burden and 

ongoing maintenance costs related to 

the requirement to perform annual 

confirmation on the dashboard. In 

addition, delegated entities such as 

filing agents will be able to use the 

‘‘view filer account information API’’ to 

programmatically check impending 

confirmation deadlines for filers that 

have delegated filing authority to 

them.283 This will allow filing agents to 

remind their client filer’s account 

administrators to perform annual 

confirmation in a timely manner.284

Filers will have the flexibility to 

perform annual confirmation on any 

date prior to the confirmation deadline, 

thus allowing filers to comply with the 

requirement at a time that is best suited 

for them and thereby lessening this 

compliance cost. Filers are required to 

authorize at least two account 

administrators to act on the filers’ behalf 

to manage their accounts and they may 

authorize up to 20 account 

administrators on the dashboard.285

Having multiple account administrators 

facilitates the management of large 

accounts since each account 

administrator will possess the same 

authority to manage the filer’s EDGAR 

account and perform the confirmation. 

This will reduce the burden on any one 

account administrator by making the 

confirmation more manageable and 

reducing the likelihood of a single 

account administrator failure. 

Furthermore, the dashboard is 

structured to facilitate the annual 

confirmation review by allowing 

account administrators to manage the 

filer’s account on the dashboard and 

through optional APIs. The optional 

APIs will enable cost efficiencies in the 

review process by allowing filers to 

rapidly add and remove individuals, 

change roles, and perform delegations to 

ensure the accuracy of information on 

the dashboard in advance of 

confirmation. 

Two commenters argued that the 

annual confirmation requirement would 

impose a significant burden on those 

who file infrequently, such as section 16 

filers.286 We do not believe that the 

annual confirmation requirement would 

impose a significant burden on 

infrequent filers, such as section 16 

filers. While section 16 filers who wish 

to act as their own account 


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287See supra note 281. 

288See supra note 282. 

289See Toppan Merrill Comment Letter (‘‘This is 

not currently a burden with the EDGAR annual 

password expiration. Filers can continue to access 

EDGAR, as well as submit filings on EDGAR, using 

a filing agent’s valid CIK and Password’’). 

290See Block Transfer Comment Letter (‘‘[W]e 

respectfully believe that automatically closing 

accounts without annual verifications as proposed 

on page 88 would hinder SBAC [Small Business 

Access to Capital] and pose an undue burden on 

American small businesses.’’). 

291See Workiva Comment Letter (‘‘We strongly 

recommend temporary suspension over account 

deactivation with removal of all user and delegation 

information. Failure to confirm annually may signal 

a problem occurred in the notification process 

rather than the filer being no longer in control of 

the account. For example, email blocking or email 

going to the spam folder could lead to the filer not 

receiving the annual confirmation reminders. It is 

also possible that the administrator(s) may be on 

leave or out of office. Based on our customer 

survey, about 23% of the respondents indicated the 

annual confirmation requirement is a low burden, 

while over 33% indicated that the annual 

confirmation requirement is a high burden and they 

are ‘‘concerned’’ to ‘‘highly concerned’’ about the 

potential account deactivation risk.’’). 

292We do not expect this programming work to 

be performed by technical administrators. As 

indicated below, we expect technical administrators 

will be operations specialists, see infra note 307. 

293The $33,000 estimate is based on the following 

calculations: $32,544 (hourly rate for a senior 

programmer analyst at $339 for 96 hours) ≈ $33,000. 

Salaries for estimates are derived from Payscale, 

available at www.payscale.com. Using data from the 

75th percentile in February 2023, adjusting for an 

1,800 hour work year and inflation, and multiplying 

by the 5.35 factor which normally is used to include 

benefits but here is used as an approximation to 

offset the fact that New York salaries are typically 

higher than the rest of the country, the result is 

$324 per hour. 

294The $41,000 estimate is based on the following 

calculations: $40,680 (hourly rate for a senior 

programmer analyst at $339 for 120 hours) ≈ 

$41,000. Salaries for estimates are derived from 

Payscale, available at www.payscale.com. Using 

data from the 75th percentile in February 2023, 

adjusting for an 1,800 hour work year and inflation, 

and multiplying by the 5.35 factor which normally 

is used to include benefits but here is used as an 

approximation to offset the fact that New York 

salaries are typically higher than the rest of the 

country, the result is $324 per hour. 

295Block Transfer Comment Letter (‘‘[T]here 

should be certain simplified endpoints which 

accept path parameters rather than raw XML. This 

would simplify the machine-to-machine reporting 

of important market information for all issuers. It 

would also drastically streamline the technical 

inclusion of route-specific authorizations). 

Despite the vast efficiencies that the detailoriented XML framework brought to the industry 

Continued 

administrators may log into the 

dashboard, review the information 

there, and proceed through a short 

confirmation process once per year, they 

may instead rely upon other 

individual(s) they authorize as account 

administrators to perform the annual 

confirmation requirement on their 

behalf. Additionally, as stated above, 

account administrators will receive 

multiple notices of the impending 

confirmation deadline via email and 

dashboard notifications,287 as well as 

the three-month grace period provided 

after the confirmation deadline has 

passed before deactivation occurs.288

These features will provide ample 

reminders to filers, including infrequent 

filers, of the annual confirmation 

requirement process. 

One commenter further stated that the 

current annual password renewal 

requirement does not represent a similar 

burden to the annual confirmation 

requirement since filers can retain their 

EDGAR access by using a filing agent’s 

CIK and password.289 As discussed 

above, all filers will receive, both via 

email and through the dashboard, 

notices of an impending confirmation 

deadline, and daily notices of failure to 

timely confirm over a three-month 

period prior to deactivation of the 

account. Further, an optional filing 

credentials API will be provided to 

allow filers that opt to connect to APIs 

to programmatically check upcoming 

confirmation deadlines. 

One commenter asserted that 

suspension of the filer’s account due to 

failure to complete the annual 

confirmation requirement by the end of 

the two-week grace period as proposed 

would pose undue burden on American 

small businesses and hinder small 

business’ access to capital.290 Another 

commenter expressed concerns about 

deactivation risk and recommended a 

temporary suspension over account 

deactivation since failure to confirm 

may result from other circumstances 

rather than account abandonment.291

We acknowledge these concerns and 

have extended the grace period 

following a missed confirmation 

deadline from two weeks to three 

months, which should help reduce the 

burdens associated with unanticipated 

account deactivation. Filers will 

maintain their EDGAR access through 

the three-month grace period and will 

receive daily notifications reminding 

them to satisfy their annual 

confirmation requirement. Further, 

following account deactivation, EDGAR 

will preserve the filer’s filing history. 

While filers with deactivated accounts 

will incur the cost of having to reapply 

for access and re-invite all individuals 

previously authorized, such burden may 

be alleviated for filers that use the APIs 

offered by EDGAR. The APIs will allow 

filers to: change individuals’ roles; send 

delegation invitations; request 

delegations; add individuals to CIKs in 

various roles; and remove individuals 

from CIKs. 

d. Optional APIs and Technical 

Administrators 

Filers or filing agents that choose to 

connect to the available APIs will incur 

a one-time cost to adjust their internal 

software systems to the optional APIs. 

We have estimated the direct costs to 

filers or filing agents that wish to 

connect to the optional APIs, including 

time and personnel costs to build a 

filing application integrated with all 

functions to successfully connect to the 

EDGAR APIs. These expenses are likely 

to vary across filers depending on their 

existing software and the complexity of 

their application and individual 

business models, among other factors. 

Based on the experience of Commission 

staff in developing the sample filing 

application to connect to certain EDGAR 

APIs being offered to filers, the total 

estimated cost per filer for filing 

applications to connect to an EDGAR 

API by an external programmer 

analyst 292 should be approximatively 

$33,000 293 for filers with a preexisting 

filing application and approximatively 

$41,000 for filers that do not have a 

preexisting filing application.294 Given 

that the APIs are optional, filers may 

choose to incur this cost to the extent 

that they expect the benefit of using the 

APIs to exceed the cost of doing so. 

Filers will need to create connections 

to the optional APIs and may modify 

other existing internal software systems 

to comport with connections to APIs. 

For filers that have been scraping 

EDGAR web pages and creating custom 

software, the one-time cost of setting up 

API connections and adjusting internal 

software systems will be mitigated by 

the elimination of these filers’ current 

ongoing maintenance costs associated 

with scraping EDGAR web pages and 

adjusting custom software each time 

EDGAR undergoes changes. Not all 

filers currently use custom software to 

interface with EDGAR, however, and 

some filers instead submit their filings 

directly through the EDGAR filing 

website. We have observed, for instance, 

that small filers typically do not use 

custom filing software and are unlikely 

to choose to connect to the optional 

APIs, therefore we do not expect they 

will incur this cost. Small filers that do 

not currently use custom software or 

lack the resources to develop their own 

API connections or employ their own 

technical administrators may use the 

APIs that their delegated entity develops 

and maintains as set forth in paragraph 

(d)(3) of Rule 10. 

One commenter recommended 

revising the APIs to accept path 

parameters rather than raw XML and to 

consider this revision in the economic 

analysis.295 The commenter asserted 


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over the past 27 years through standardized 

reporting, we respectfully submit to the 

Commission that the markup language is not 

friendly to developers, international locale 

standards, or efficient machine-to-machine code. 

Modern APIs use path parameters, eliminating the 

need to compile variables into a file before 

submission.’’). 

296 Id. 

297See DFIN Comment Letter (‘‘Estimated cost 

should include the likelihood that filing agents 

would need to update or create an application to 

manage delegations.’’). 

298See Proposing Release, section III.C.1; see also 

supra section II.C.1. 

299See Workiva Comment Letter (‘‘If an actual 

user must be associated with the process due to the 

need to present a user token, this could potentially 

impose additional services . . .’’); (‘‘In our opinion, 

the development time estimate of 96–120 hours is 

a very low estimate. Considering the API integration 

time, the software changes for token management 

and filing preparation, customer discovery and beta 

testing time, the estimate could be an order of 

magnitude higher. In addition, monitoring and 

adapting to changes in the EDGAR Next beta 

environment will incur ongoing costs through 

March 2024. The economic [ ] analysis also does not 

include the additional non-developmental support 

costs imposed on filing agents and law firms . . .’’). 

300See Workiva Comment Letter (‘‘[c]hange of 

provider could require longer lead time due to the 

delegation set up and acceptance process, as well 

as making the tokens available in the filing systems. 

This could put pressure on the filers when they 

need to respond to unforeseen situations.’’). 

301See Workiva Comment Letter and XBRL 

Comment Letter. 

302See Workiva Comment Letter (‘‘the potential 

impact on increased manual intervention resulting 

in higher services costs, which are hard to 

accurately estimate at this point although we expect 

it to be far reaching due to the percentage of public 

registrants potentially impacted by this.’’). 

that modern APIs use path parameters 

and implementing path parameters in 

the APIs would simplify machine-tomachine information retrieval as 

opposed to raw XML, which the 

commenter stated is not friendly to 

developers.296 This comment does not 

accurately reflect the nature of the APIs 

that are being provided by Commission 

staff. The APIs, as designed, will take 

advantage of path parameters, which 

should largely address the commenter’s 

concerns. Path parameters are intended 

to be used to identify specific resources 

or data points, such as a filer’s CIK, and 

they are not suitable for providing 

complex nested data, such as the 

information that would be required to 

be included in an EDGAR submission. 

In those cases, XML is better suited for 

providing structured data in a format 

that can be easily interpreted and 

accepted by the APIs. Commission staff 

have developed the APIs accordingly. 

A commenter stated that the 

economic analysis in the Proposing 

Release failed to account for the costs of 

filing agents likely needing to update or 

develop an application to manage 

delegation.297 We disagree with the 

commenter that this is a significant cost 

that should have been accounted for in 

the Proposing Release. Because EDGAR 

Next already offers multiple ways to 

manage delegations, we do not believe 

that filers and filing agents will need to 

update or develop an application for 

this purpose. As stated in the Proposing 

Release and herein, the filer’s account 

administrator may delegate authority to 

file to another EDGAR account through 

a function on the dashboard where they 

can also terminate delegation.298 The 

dashboard will be enhanced to: (1) 

provide bulk delegation functionality to 

allow filers to delegate to multiple CIKs 

more easily; (2) enable prospective 

delegated entities to send delegation 

requests to filers; and (3) allow filers to 

automatically accept delegations and 

become delegated entities if they 

choose. These three enhancements are 

available on the dashboard, and do not 

require creation or updating of an 

application. Moreover, for filers that opt 

to use the available APIs, an optional 

delegation API will also be offered 

replicating most dashboard 

functionality in machine-to-machine 

connections. Although filers who wish 

to use the delegation API will need to 

create connections to the API to do so, 

this is no different from how filers will 

connect to the other APIs and we do not 

expect any unique costs will apply in 

this context. Account administrators 

will be able to delegate authority to file 

to an unlimited number of EDGAR 

accounts, allowing filers to delegate to 

multiple filing agents, for example. 

Another commenter stated that the 

proposed API connective software 

development time was overly 

optimistic, and that the proposal’s costs 

estimates failed to account for many 

important items, such as API integration 

time, the software changes for token 

management and filing preparation, 

customer discovery and beta testing.299

We agree with the commenter that API 

connective software development time 

should encompass API integration time, 

the software changes for token 

management and filing preparation, 

customer discovery and beta testing. 

Our cost estimate in the proposal and 

herein captures these items. First, our 

cost estimate assumes that the sample 

application will be built from scratch 

with no documentation or open-source 

code base. Second, our estimate 

includes building a basic application 

with limited user interface functions 

that submits LIVE and TEST filings and 

requests system status and submission 

status from the EDGAR API, which are 

essential for beta testing and filing 

preparation. To further facilitate API 

integration time and mitigate some of 

the aforementioned development costs, 

Commission staff will offer filers 

technical resources, such as an API 

Development Toolkit and a sample 

filing application, to assist filers in 

developing their own connective filing 

software. The sample filing application 

will provide technical details and a 

working code base that could be either 

copied into existing filing applications 

or used as a base for developing a new 

filing application. The sample filing 

application code is a starting point for 

smaller filers that may not already have 

a filing application and want to enter 

the API space. This sample code can 

serve as a troubleshooting guide/ 

reference material for all developers 

because it uses specific technologies 

(e.g., PostgreSQL, NodeJS, Angular) that 

are well-documented, commonly used, 

and can be understood by a mid-level 

programmer. 

One commenter questioned the 

implementation of filer and user tokens 

within the delegation framework and 

asserted that the EDGAR Next 

framework could lead to longer filing 

preparation time and hinder the 

efficiency of an automated filing 

process.300 To address the commenter’s 

concern, and in a change from the 

proposal, filers that utilize a delegated 

entity also have, under the final 

amendments, the option of using a 

delegated entity’s filer API token and 

API connections to make submissions 

on behalf of the filer, so long as the 

delegated entity has authorized at least 

two technical administrators in 

accordance with paragraph (d)(3) of 

Rule 10. This change may further serve 

to mitigate concerns about development 

costs. As a result, APIs may be more 

accessible for smaller filers that may not 

have the resources to develop API 

connections or employ their own 

technical administrators, as they may 

instead delegate to a larger filer or filing 

agent that can develop API connections 

and obtain and maintain filer API 

tokens and two technical 

administrators. 

Two commenters were critical of the 

proposal’s use of filer and user 

tokens.301 One commenter claimed the 

use of specific user tokens would 

subject filing agents to a higher cost of 

service and longer filing preparation 

lead time.302 We do not think the use of 

specific user tokens is unduly 

burdensome for filers that choose to 

make submissions through APIs. 

Generating a filer API token or a user 

API token is a straightforward process 

accomplished on the dashboard within 

approximately one minute of logging in. 

Furthermore, the use of tokens to 


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303See Workiva Comment Letter (‘‘We believe a 

user role that has only the authority to file and 

manage its credentials and membership is 

appropriate. However, one proposed requirement 

for users is to log into one of the three EDGAR sites 

at least once every 30 days in order to keep the user 

token active. According to our customer survey, 

about 72% of the respondents indicated that this 

requirement poses a significant burden or risk to 

their filing teams.’’); Block Transfer Comment Letter 

(‘‘We respectfully submit to the Commission that 

development based access keys should not be 

subject to monthly user MFA checks. We believe 

that imposing such checks on these keys may 

introduce unnecessary complexities and hinder the 

efficiency of development teams working on 

various projects.’’). 

304See XBRL Comment Letter (‘‘Furthermore, the 

changes to securely store and manage Filer and 

User Tokens could easily add 240 developer 

hours.’’). 

305See supra notes 293 and 294, estimating 96 

hours for filers with an existing filing application 

and 120 hours for filers that do not have a 

preexisting filing application. 

306See paragraph (d)(3) of Rule 10 as adopted. 

307The $170 estimate is based on the following 

calculations: $168 (hourly rate for an operations 

specialist at $168 for 1 hour) ≈ $170. Salaries for 

estimates are derived from SIFMA’s Management & 

Professional Earnings in the Securities Industry 

2013, modified to account for an 1,800-hour workyear and inflation, and multiplied by 5.35 to 

account for bonuses, firm size, employee benefits 

and overhead. These represent costs beyond the 

quantified costs for technical administrators that are 

associated with dashboard management. See supra 

note 275 for an estimate of the annual cost of 

dashboard management. Based on Commission staff 

experience and knowledge regarding the filing 

agent industry, we estimate there will be 208 filers 

that will be required to satisfy the technical 

administrator requirements. 

308 XBRL Comment Letter (‘‘There is also an 

estimated 8 hours per week to track changes in the 

beta through March 2024.’’). 

connect to APIs is a security 

requirement designed to minimize the 

potential for unauthorized intrusions to 

EDGAR. In addition, presentation of the 

individual’s user API token allows the 

Commission to identify who makes each 

submission on EDGAR, a primary goal 

of this rulemaking. Removing the user 

API token requirement would frustrate 

the Commission’s objective of 

enhancing the security of EDGAR and 

tracing filings to the individuals who 

make them. 

Two commenters argued that the 

monthly user multifactor authentication 

login requirement would create a 

significant burden for their filing teams 

and their section 16 filers.303 In a 

change to the proposing release, rather 

than the user API token remaining valid 

for up to one year so long as the user 

logged into EDGAR at least every 30 

days, the individual will need to log in 

to generate a new user API token every 

30 days or otherwise prior to making an 

infrequent filing. While we 

acknowledge that the requirement that a 

person log in to generate a new user API 

token every 30 days (if necessary to 

make a filing) may inconvenience some 

filers, the cost of this burden will not be 

significant because generating a user 

API token is a straightforward process 

accomplished on the dashboard. We 

estimate that a user API token could be 

generated within approximately one 

minute of logging into the dashboard. 

Section 16 filers may either authorize an 

individual at their filing agent or other 

third party to enroll them in EDGAR 

Next and during enrollment authorize 

one or more individuals at these entities 

to act as their account administrators or, 

when applying for access on amended 

Form ID, authorize individuals at their 

filing agents or other representative 

entity as their account administrators 

using a notarized power of attorney, 

each of whom may file on their behalf. 

Also, any incremental burdens imposed 

by the monthly user multifactor 

authentication login requirement must 

be considered in light of the potential 

benefits it will provide. User API tokens 

will enhance authentication, provide 

traceability for filings, and improve 

EDGAR security. 

Another commenter estimated a total 

of 240 developer hours towards securely 

storing and managing the filer and user 

API tokens.304 We believe, however, 

that the commenter’s estimate of 240 

additional developer hours due to the 

API token requirements is likely 

overstated. As discussed above, we 

estimate that it will take between 96 and 

120 hours to configure the filer’s filing 

application correctly to be able to 

interact with the API.305 This estimate 

includes the time that filers will spend 

to implement a method to store the 

tokens in a database and to use the 

tokens within filers’ applications to 

connect to the EDGAR APIs. Thus, we 

believe that the API application 

development cost estimate provided 

above already adequately incorporate 

the above steps of integrating and 

managing the API tokens. 

Filers that choose to connect to the 

APIs will also incur the additional cost 

of authorizing, through their account 

administrator(s), at least two technical 

administrators to manage the technical 

aspects of the APIs.306 The Commission 

estimates that annually, on average, 

each filer that chooses to connect to the 

APIs will incur approximately $170 in 

compliance costs per CIK with respect 

to the technical administrators’ 

responsibilities.307 These costs may vary 

depending on the size of the filer, the 

number of filer API tokens the filer 

employs at any given time, and the 

business needs of the filer with regards 

to the usage and management of APIs 

(including but not limited to the 

security standards imposed by the filer). 

We do not expect that filers will need 

to hire new employees to fill the 

technical administrator role since the 

primary responsibilities for the 

technical administrator are to generate 

the filer API token on an annual basis 

and securely store it within a filer’s 

application and to be available in the 

event that a technical issue arises with 

APIs. We believe that larger filers and 

filing agents using APIs will have 

sufficient staff to authorize at least two 

technical administrators. Smaller filers 

who choose to connect to APIs will 

likely employ a delegated entity to 

avoid the burden of obtaining and 

maintaining their own filer API tokens, 

engineering their own API connections, 

and designating two technical 

administrators. Final paragraph (d)(3) of 

Rule 10’s requirement that a filer 

authorize, through its account 

administrator(s), at least two technical 

administrators will not apply to a filer 

that uses the filer API token and API 

connections of its delegated entity, so 

long as the delegated entity has 

authorized its own technical 

administrators in accordance with 

paragraph (d)(3) of Rule 10. Filers that 

rely upon their delegated entity’s filer 

API token and API connections will not 

need to obtain and maintain their own 

filer API tokens or engineer their own 

API connections, although their account 

administrators and users will need to 

supply their own user API tokens to the 

APIs, if those APIs require presentation 

of a user API token. 

e. Adopting Beta and Transition Period 

During the transition process to 

EDGAR Next, filers will incur certain 

ancillary costs related to testing and 

quality assurance. These costs may also 

include documentation and technical 

support cost for personnel managing the 

transition at the filer. For example, one 

commenter estimated 8 hours per week 

to track changes in the Proposing Beta 

through March 2024.308 We expect that 

there will be a similar cost to track 

changes in the Adopting Beta. However, 

to help mitigate some of these costs, 

Commission staff will provide dedicated 

telephone support and an email help 

desk—EDGARNextBeta@sec.gov—as 

well as an online form (available in the 

Adopting Beta) to report technical bugs. 

A more improved user experience will 

ultimately reduce the possibility of 

errors and disruption for filers, thus 

minimizing the cost burden associated 

with transitioning to the new filing 

regime. The Adopting Beta will help 


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309Workiva Comment Letter (‘‘As discussed in 

the response to question 35, sweeping changes to 

CCC is a big disruption and risk factor to the filing 

chain. Coordination issues could be easily 

resolvable on a small scale, but at this large scale 

even for filing agents that have been delegated to 

or added as account administrators, the time 

requirement to log in and view CCC changes could 

significantly impact filing lead time given the 

volume and the concentration of these issues.’’). 

310Cadwalader Comment Letter (‘‘On an 

operational level, we do not expect individual serial 

trusts to have account administrators, technical 

administrators, users or delegated entities that are 

not also performing the same functions for the 

depositor, although the depositor may have certain 

additional account administrators, technical 

administrators, users or delegated entities who are 

not assigned to all of the related serial trusts. 

Therefore, depositor-level confirmation of its 

authorized parties would also encompass all 

individuals assigned roles with respect to each 

individual serial trust.’’); Toppan Merrill Comment 

Letter (responding to a question regarding whether 

bulk confirmations should be permitted by stating 

‘‘[y]es, affiliated filers with the same administrators, 

users, delegations, and corporate and contact 

information should be allowed similar functionality 

. . .’’). 

311See supra section II.B.1. 

minimize disruptions to the filing 

processes for all filers. 

Filers will have six months prior to 

the compliance date and three months 

after the compliance date within which 

to enroll through a function on the 

dashboard. Once a filer enrolls in 

EDGAR Next, the filer’s CCC will be 

automatically reset. One commenter 

stated that requiring the CCC to be reset 

after a filer enrolls will negatively 

impact filing preparation lead time as 

individuals must first log in to view any 

CCC changes before submission.309 We 

disagree with the commenter’s 

characterization of the additional cost 

associated with viewing any CCC 

changes. To protect the security of the 

filer’s EDGAR account, EDGAR will 

automatically reset the filer’s CCC 

following the filer’s enrollment in 

EDGAR Next. To leave the CCC 

unchanged after enrollment would 

frustrate the Commission’s effort to 

enhance the security of EDGAR. We do 

not expect a one-time reset of the filer’s 

CCC to cause any major disruptions 

because filers should be aware that the 

CCC will change and that they can 

manage it themselves on the dashboard 

after enrollment. To reduce the cost 

associated with resetting the CCC, the 

new CCC will be visible on the 

dashboard to all individuals with the 

ability to make submissions on the 

filer’s behalf. Further, EDGAR will offer 

APIs to view filer account information 

and verify filing credentials, including 

the filer’s CCC. We therefore do not 

believe that resetting the CCC upon 

enrollment will negatively impact filing 

preparation lead time. 

3. Effects on Efficiency, Competition, 

and Capital Formation 

The final amendments will enhance 

the security of EDGAR by improving the 

security of submissions, the individual 

traceability of filings, and regulatory 

oversight into filings. The amendments 

will also streamline the filing process, 

including filing preparations, and 

enhance the efficiency of the 

Commission’s review and processing of 

EDGAR submissions. The amendments 

therefore will better protect against 

unauthorized access to filers’ accounts 

and unauthorized filings on the EDGAR 

system. This will reduce the risk that 

unauthorized access and filings disrupt 

market efficiency and affect capital 

formation by affected filers. The 

amendments will also enhance investor 

confidence in, and therefore use of, the 

financial information available through 

EDGAR filings, thereby helping 

investors make more informed 

investment decisions. 

We do not expect the EDGAR Next 

changes to impact competition because 

the final rules and amendments are 

designed to impose modest compliance 

costs, which are largely one-time in 

nature and not expected to significantly 

affect small filers. As discussed in 

sections IV.B.2.d and IV.B.2.c, the 

Commission is making certain technical 

resources available to all filers in 

connection with the final amendments, 

such as optional APIs and open-source 

software to connect to certain APIs, 

which should mitigate compliance 

costs, including for small filers. Larger 

filers and filing agents could experience 

ongoing compliance cost savings under 

EDGAR Next due to the streamlined 

management of filer credentials and 

accounts, simplified access procedures, 

and greater automation of the filing 

process and preparation. This need not 

disproportionately disadvantage smaller 

filers, however, as smaller filers will 

have the option to rely on delegated 

entities to supply API connections and 

filer API tokens. To the extent that, as 

discussed above, delegated entities 

experience ongoing compliance cost 

savings under EDGAR Next, then 

competition among delegated entities 

may lead them to pass on some of these 

cost savings to their clients in the form 

of lower fees, including to smaller filers. 

C. Reasonable Alternatives 

1. Add and Allow Bulk Confirmation for 

Related CIKs 

As adopted, paragraph (d)(4) of Rule 

10 will require each filer to perform an 

annual confirmation on EDGAR of all of 

the filer’s users, account administrators, 

technical administrators, and delegated 

entities, as well as any other 

information related to the filer 

appearing on the dashboard. Several 

technical features will be introduced to 

facilitate compliance with the rule and 

form requirements. For example, bulk 

enrollment will permit filers and filing 

agents to simultaneously enroll up to 

100 filers, along with their authorized 

account administrators, in a single 

batch. Several commenters suggested 

that the Commission should also allow 

bulk confirmations to be performed for 

related CIKs, such as CIKs that share the 

same administrators, users, delegations, 

and corporate and contact 

information.310 This alternative might 

facilitate the confirmation of multiple 

filers simultaneously, but the annual 

confirmation for related CIKs does not 

lend itself to bulk processing. While 

some related CIKs may share the same 

administrators, users, delegations, and 

corporate and contact information, not 

all of them do. Related CIKs (such as 

CIKs for co-registrants or filers with 

beneficial ownership obligations) will 

often have different information that is 

to be provided on the dashboard; for 

example, co-registrants may have 

different individuals authorized to act 

on their behalf.311 Thus, adding a bulk 

confirmation feature for related CIKs 

could lead to the inadvertent 

confirmation of dashboard information 

without proper review and verification 

for accuracy, thus undermining the 

intended benefits of the annual 

confirmation requirement. For this 

reason, we are not implementing this 

alternative. Filers may already achieve 

under EDGAR Next efficiencies in the 

confirmation process by leveraging the 

newly added APIs that will allow them 

to reduce confirmation preparation lead 

time by rapidly adding and removing 

individuals, changing roles, and 

performing delegations in advance of 

confirmation. 

2. Extend the ABSCOMP Process to 

Affiliated Entities 

EDGAR permits certain filings to be 

submitted on behalf of multiple filers, 

that are treated as co-registrants for 

purposes of the filing. Examples of 

several types of issuers that manage and 

file with related entities include 

investment companies filing on behalf 

of other affiliated investment 

companies, corporate issuers with 

co-registrants, beneficial ownership 

reporting filers (e.g., Form 144, 

Schedule 13D, Schedule 13G, and 

section 16 filers), and ABS issuers. 

While these registrants have a separate 

CIK for each filer, they are managed by 

one entity. In particular, ABS issuers, 


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312See Toppan Merrill Comment Letter (‘‘The 

proposed functionality for an ABS account 

administrator to access the dashboard for serial 

companies could be utilized for other issuers who 

have a related structure with multiple entities . . . 

including corporate issuers with co-registrants [and] 

beneficial ownership reporting filers. . . . If the 

existing option to create a serial company by the 

‘ABSCOMP’ process is available in EDGAR Next 

functionality that will be sufficient for ABS entities 

to manage creating new CIKs.’’). 

313See supra section II.A. 

314See supra note 123. 

315As discussed above in section IV.B.2.d, while 

we do not expect smaller entities to develop their 

own software, they may be able to use the optional 

APIs of a delegated entity pursuant to adopted 

paragraph (d)(3) of Rule 10. 

316SCG Comment Letter (‘‘We also ask that the 

Commission consider allowing all Section 16 filers 

to continue to use the existing EDGAR system for 

an additional six months after the enrollment 

period ends, so they do not miss any deadlines 

while they enroll in EDGAR Next.’’) (emphasis in 

original). 

317See supra note 48. 

usually the depositor in an ABS 

transaction, may create multiple serial 

companies each year, each of which 

represents a distinct legal entity with its 

own CIK, even though each generally 

has the same contact information as the 

ABS issuer. The ABSCOMP process 

streamlines the ABS issuer’s submission 

process, by allowing for rapid creation 

of multiple serial companies and by 

automatically copying all account 

information associated with the ABS 

issuing entity to any created serial 

companies. 

One commenter recommended 

expanding the ABSCOMP process to 

other issuers that have a related 

structure with multiple related 

parties.312 This alternative, however, 

would not provide the same benefits to 

filers with related party structure as it 

does for ABS issuers because the same 

dashboard information would be 

disseminated to all related entities 

involved in the ABSCOMP process. 

While ABS issuers and their serial 

companies share the same underlying 

dashboard information, other related 

party entities, such as investment 

companies and co-registrants, do not 

share this characteristic, as each of these 

filers typically possesses separate filerspecific information such as name, 

address, and contact information, as 

well as separate reporting obligations. 

Thus, expanding the ABSCOMP process 

to other related party filers could 

increase the risk of filing errors and 

inconsistencies, resulting in additional 

administrative burden and delays in the 

submission process for the related party 

filers in scope. For this reason, we are 

not implementing this alternative. The 

added APIs under EDGAR Next should 

already substantially address the 

commenter’s concerns by allowing filers 

to rapidly add account administrators 

and make other changes as necessary, as 

discussed further in section II.E above. 

3. Retire the CCC for Filing Submissions 

The final amendments will maintain 

the CCC as the code required for filing. 

The CCC code will be displayed on the 

dashboard. Alternatively, one 

commenter suggested eliminating the 

use of a filer’s CCC to submit a filing. 

The commenter stated that the CCC 

requirement will be redundant as 

individuals accessing the CCC through 

the dashboard will also need to sign in 

with their respective individual account 

credentials, complete multifactor 

authentication, and be authorized by the 

filer. 

Retiring the CCC could result in a 

modest efficiency gain for filers by 

eliminating the additional step of 

presenting the CCC as a requirement for 

submission authorization resulting in a 

moderate reduction in submission 

preparation time. The CCC could be 

eliminated in the future if feasible from 

a technical and security standpoint.313

At this time, however, we continue to 

believe that the required use of the CCC 

enhances submission security. 

Moreover, some commenters 314

expressed their preferences for 

maintaining the current co-registrant 

filings process unchanged, and this 

process requires both the CCC and CIK 

for submission success. Also, EDGAR 

Next will introduce a view account 

information API that will allow filers 

and filing agents to view the filer’s CCC 

via an API (so long as the user API token 

belongs to an individual who has 

permissions to view the CCC and use 

the filer API token). Facilitating access 

to the CCC via the dashboard and the 

APIs should ease the burden of 

submitting the CCC for each filing. 

4. Requirements for Individual and 

Small Filers 

EDGAR Next will apply to all 

prospective and existing filers 

regardless of size. Alternatively, the 

Commission could implement scaled 

requirements for small entities and 

individual filers. For example, the 

Commission could consider exempting 

section 16 filers from amended 

paragraph (d)(4) of Rule 10(d)(4), which 

will require filers, through their 

authorized account administrators, to 

confirm annually that all account 

administrators, users, and delegated 

entities, and technical administrators 

reflected on the dashboard for the filer’s 

EDGAR account are authorized by the 

filer and that all information regarding 

the filer on the dashboard is accurate. 

Further, the Commission could exempt 

small filers from amended paragraph 

(d)(1) of Rule 10(d)(1), and instead allow 

small filers to independently develop 

practices and recordkeeping to track 

individuals acting on their behalf and 

safeguard their account access codes. 

Such scaled requirements would lower 

the compliance costs for small entities 

and individual filers. 

Exempting any subgroup of filers from 

paragraph (d)(1) or (d)(4) of Rule 

10(d)(1) or Rule 10(d)(4), or the other 

EDGAR Next changes, would lessen the 

security benefits of EDGAR Next with 

regard to these filers. The EDGAR Next 

changes are designed to enhance the 

security of EDGAR filings, including by, 

among other things, strengthening the 

security of access to filers’ EDGAR 

accounts by establishing a uniform 

method for authorizing, identifying, and 

tracking all individuals authorized to 

act on each filer’s behalf. Exempting 

small filers from obtaining individual 

account credentials would increase the 

risks that small entities and individual 

filers are subject to unauthorized access 

to their EDGAR accounts and 

unauthorized filings, thereby 

undermining the benefits of EDGAR 

Next. Also, as discussed in sections 

IV.B.2.d and IV.B.2.c, (the Commission 

is making certain technical resources 

available to filers in connection with the 

final amendments, such as optional 

APIs,315 the Adopting Beta, and a 

transition period, all of which should 

help mitigate compliance costs for 

smaller entities and individual filers. 

As another alternative, the 

Commission could allow smaller filers 

additional time to come into 

compliance. One commenter suggested 

that Section 16 filers be granted an 

additional six months after the 

enrollment period ends so that they do 

not miss any deadlines while they 

enroll in EDGAR Next.316 A longer 

enrollment period would lower the 

compliance cost for small filers by 

enabling a transition to EDGAR Next at 

a pace that suits their needs, allowing 

these filers with fewer resources more 

time to adapt to the new requirements. 

EDGAR Next will allow filers an 

additional three months after 

compliance within which to enroll, 

although the legacy filing regime will 

not be extended beyond the compliance 

date. Extending the legacy filing regime 

would lessen the security benefits of 

EDGAR Next by delaying the 

implementation of the multifactor 

authentication and individual account 

credential requirements.317


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318See supra notes 29 and 30 and accompanying 

text. 

319 44 U.S.C. 3501 et seq. 

320 44 U.S.C. 3507(d); 5 CFR 1320.11. 

321See Block Transfer Comment Letter. 

322The burden represents an estimate of the 

average compliance burden. Consequently, the 

burden could be lower for some filers (such as those 

that do not need to add notarizations for account 

administrators), and higher for other filers (such as 

those that do need to include notarizations for 

account administrators). 

323See comment Letter of Akash Chand 

(September 13, 2023). 

Nevertheless, filers who must make a 

required filing within three months after 

the compliance date, and who have not 

yet enrolled, will be able to quickly 

enroll and access their EDGAR accounts 

in order to make timely submissions. 

5. Implementing Performance-Based 

Standards 

EDGAR Next mandates certain 

prescribed requirements to enhance the 

security of EDGAR’s filing regime. We 

could consider an alternative with a 

more performance-based approach that 

would not spell out the precise actions 

filers need to take in order to improve 

the security of EDGAR. For instance, we 

could simply state that filers should 

have practices and recordkeeping that 

allow the Commission to more easily 

identify anyone who takes action on 

EDGAR on the filer’s behalf and also 

ensure that only individuals authorized 

by the filer are privy to the filer’s access 

codes. This could, for instance, lead 

beneficial ownership reporting filers to 

opt to forgo authorizing account 

administrators to manage their EDGAR 

account, or other filers could determine 

that they do not need multifactor 

authentication for designated 

individuals authorized to act on their 

behalf on the dashboard. 

The benefits of a more performancebased approach would be that filers 

would have more flexibility in what 

their practices and recordkeeping cover. 

For instance, they could tailor their 

EDGAR access compliance requirements 

to their specific circumstances and have 

greater discretion in how they manage 

their EDGAR accounts and safeguard 

their account access codes. While this 

approach would provide more 

flexibility for filers, we are not 

implementing this alternative as 

allowing individual filers to decide 

which security measures to implement 

would undermine our objective of 

enhancing the existing security 

requirements for the EDGAR system. In 

particular, individual account credential 

requirements, including multifactor 

authentication, are a key security 

enhancement that allows us to 

modernize and implement stronger 

cybersecurity standards, consistent with 

current best practices, as described in 

Executive Order No. 14028 and the 

NIST guidelines.318

V. Paperwork Reduction Act 

Certain provisions of our rules and 

forms that will be affected by the final 

amendments contain ‘‘collection of 

information’’ requirements within the 

meaning of the Paperwork Reduction 

Act of 1995 (‘‘PRA’’).319 The 

Commission published a notice 

requesting comment on changes to these 

collection of information requirements 

in the Proposing Release and submitted 

these requirements to the Office of 

Management and Budget (‘‘OMB’’) for 

review in accordance with the PRA.320

An agency may not conduct or sponsor, 

and a person is not required to respond 

to, a collection of information unless it 

displays a currently valid OMB control 

number. Compliance with the 

information collection is mandatory. 

Responses to the information collection 

are not kept confidential, and there is no 

mandatory retention period for the 

information disclosed. The title for the 

existing collection of information that 

we are amending is ‘‘Form ID—EDGAR 

Password’’ (OMB Control No. 3235– 

0328). We also are adding a new 

collection of information titled ‘‘the 

dashboard.’’ The final amendments to 

Form ID and the implementation of the 

dashboard are designed to harness the 

benefits of improved technology and to 

modernize the EDGAR access and 

account management functions. A 

detailed description of the final 

amendments, including the 

amendments to Form ID and the 

implementation of the dashboard, 

including the need for the information 

and its intended use, as well as a 

description of the likely respondents, 

can be found in section II above, and a 

discussion of the expected economic 

impact of the amendments can be found 

in section IV above. 

A. Summary of Comment Letters on 

PRA Estimates 

In the Proposing Release, the 

Commission requested comment on the 

PRA burden hour and cost estimates 

and the analysis used to derive the 

estimates. We received two comment 

letters addressing the PRA estimates. 

One letter inquired whether notarization 

had been accounted for in our burden 

estimates.321 We affirm that the PRA 

estimates, both previously approved by 

OMB and the estimates contained in 

these final amendments, reflect the 

overall burden of compliance with Form 

ID, including the notarization 

requirements.322 The second letter 

recommended that the amendments 

lead to an update to the ‘‘Paperwork 

Reduction Act’’ as it will require more 

filings by companies through 

EDGAR.323 To the extent that the filer 

was referring to the PRA burden 

estimates associated with EDGAR Next, 

as discussed below, we are revising 

those estimates to reflect the EDGAR 

Next changes, although we do not 

expect the EDGAR Next changes to 

cause a significant increase in the 

number of filings on EDGAR. 

B. Form ID 

Form ID must be completed online 

and submitted to the Commission by 

individuals, companies, and other 

organizations that seek access to file 

electronically on EDGAR. 

As outlined above, the final 

amendments to Form ID will require an 

applicant for EDGAR access to 

undertake certain additional obligations, 

including most significantly: (1) 

designating on Form ID specific 

individuals the applicant authorizes as 

its account administrator(s) to manage 

its EDGAR account on a dedicated 

dashboard on EDGAR; (2) indicating the 

applicant’s LEI, if any; (3) providing 

more specific contact information about 

the filer, its account administrator(s), its 

authorized individual (the individual 

authorized to sign Form ID on the filer’s 

behalf as defined in the EDGAR Filer 

Manual), and its billing contact 

(including mailing, business, and billing 

information, as applicable); (4) 

specifying whether the applicant, its 

authorized individual, person signing a 

power of attorney (if applicable), 

account administrator, or billing contact 

has been criminally convicted as a 

result of a Federal or State securities law 

violation, or civilly or administratively 

enjoined, barred, suspended, or banned 

in any capacity, as a result of a Federal 

or State securities law violation; (5) 

indicating whether the applicant, if a 

company, is in good standing with its 

State or country of incorporation; (6) 

requiring submission of a new Form ID 

for both prospective filers seeking 

access to EDGAR for the first time and 

existing filers that must apply for access 

to EDGAR because they: (i) are the legal 

successor of the filer named on the 

existing CIK account but did not receive 

access from that filer, (ii) lost electronic 

access to their existing CIK account, or 

(iii) are broker-dealers or ‘‘paper filers’’ 

seeking electronic access for the first 

time in order to file electronically on 

EDGAR; and (7) requiring those seeking 

access to an existing EDGAR account to 


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324 48,089 filings for users without CIKs + 8,836 

filings for filers who are seeking to regain access to 

EDGAR + 404 filings for filers with CIKs who have 

not yet filed electronically on EDGAR = 57,329 

filings. 

325 63,676 filings for users without CIKs + 9,602 

filings for filers who are seeking to regain access to 

EDGAR + 322 filings for filers with CIKs who have 

not yet filed electronically on EDGAR = 73,600 

filings. 

326The increase in burden will vary by applicant 

depending on whether certain of their responses 

required additional information (e.g., explaining the 

circumstances surrounding any specified 

individuals who are currently subject to Federal or 

State securities law investigations, proceedings, 

convictions, suspensions, or bars, and for 

applicants seeking access to an existing CIK 

account, providing the documents that establish the 

applicant’s authority over the company or 

individual currently listed in EDGAR as 

corresponding to the existing CIK account). 

327 73,600 filings × 0.60 hours/filing = 44,160 

hours. 

upload to EDGAR the documents that 

establish the applicant’s authority over 

the company or individual listed in 

EDGAR on the existing account. The 

final amendments will also simplify 

filer account management by 

eliminating the EDGAR password, 

PMAC, and passphrase. 

For purposes of the Paperwork 

Reduction Act, the currently approved 

collection of information includes an 

estimate of 57,329 Form ID filings 

annually and further estimates 

approximately 0.30 hours per response 

to prepare and file Form ID, for a total 

of 17,199 annual burden hours. Those 

estimates include the number of Form 

ID filings for filers without CIKs (48,089 

filings), filers with CIKs that are seeking 

to regain access to EDGAR (8,836 

filings), and filers with CIKs that have 

not filed electronically on EDGAR (404 

filings).324 These estimates assume that 

filers are responsible for 100% of the 

total burden hours. 

There were 73,600 Form ID filings in 

calendar year 2023. The estimate 

includes the number of filers without 

CIKs, filers with CIKs that have not filed 

electronically on EDGAR, and filers 

with CIKs that are seeking to regain 

access EDGAR.325 For purposes of the 

Paperwork Reduction Act, we estimate 

that the number of Form ID filings 

under the final amendments will remain 

the same and that the number of hours 

to prepare Form ID will increase by 0.30 

hours as a result of the adoption of the 

access changes and Form ID 

amendments.326

Thus, for purposes of the Paperwork 

Reduction Act, the estimated total 

number of annual Form ID filings will 

increase from 57,329 filings to 73,600 

filings. The estimate of 0.30 hours per 

response will increase to 0.60 hours per 

response. The estimated total annual 

burden will increase from 17,199 hours 

to 44,160 hours.327 The estimate that the 

filers are responsible for 100% of the 

total burden hours will remain the 

same. 

C. The Dashboard 

As outlined above, pursuant to 

paragraph (d) of Rule 10 as adopted 

each filer will be required to authorize 

individuals to act on its behalf on the 

dashboard, and those individuals must 

have obtained individual account 

credentials for EDGAR in the manner 

specified in the EDGAR Filer Manual. 

Moreover, pursuant to paragraph (d) of 

Rule 10 as adopted, each filer, through 

its account administrators, will be 

required to: (i) authorize and maintain 

at least two individuals as authorized 

account administrators to act on the 

filer’s behalf to manage the filer’s 

EDGAR account, except a filer who is an 

individual or single-member company 

must authorize and maintain at least 

one individual as an account 

administrator; (ii) confirm annually on 

EDGAR that all users, account 

administrators, technical administrators, 

and/or delegated entities reflected on 

the dashboard for the filer’s EDGAR 

account are authorized by the filer, and 

that the filer’s information on the 

dashboard is accurate; (iii) maintain 

accurate and current information on 

EDGAR concerning the filer’s account, 

including but not limited to accurate 

corporate information and contact 

information (such as mailing and 

business addresses, email addresses, 

and telephone numbers); (iv) securely 

maintain information relevant to the 

ability to access the filer’s EDGAR 

account, including but not limited to 

access through any EDGAR API; and (v) 

if the filer chooses to connect to an 

EDGAR API, authorize, through its 

account administrator(s) at least two 

technical administrators to manage 

technical matters related to the filer’s 

connection to the API, or the filer may 

use the API connections and filer API 

tokens of its delegated entity so long as 

the delegated entity is in compliance 

with the technical administrator and 

other API requirements. 

EDGAR will facilitate account 

administrators’ management of filers’ 

accounts by allowing them to: (i) add 

and remove users, account 

administrators, and technical 

administrators (including removing 

themselves as an account 

administrator); (ii) create and edit 

groups of users; (iii) delegate filing 

authority to other EDGAR accounts and 

remove such delegations; (iv) generate a 

new CCC; and (v) receive notifications 

regarding significant events affecting the 

account (which will also be provided 

via email to the account administrators’ 

email addresses). 

For purposes of the PRA, we estimate 

that each filer will spend approximately 

one hour in the first year setting up the 

dashboard, and additionally, on average, 

approximately one hour per annum 

managing the filer’s account on the 

dashboard. This burden will vary across 

filers depending on the size of the filer, 

the number of users, account 

administrators, technical administrators, 

and delegated entities authorized by the 

filer, as well as the amount of annual 

staff turnover for those individuals and 

entities, among other factors. For a small 

number of filers, the annual burden may 

significantly exceed our estimate (e.g., 

filing agents that may authorize a large 

number of individuals and that have 

multiple accepted delegations and user 

groups for which delegated users will 

need to be maintained). On the other 

hand, for the vast majority of filers, the 

annual burden will presumably be less 

than our estimate because we expect 

most filers will authorize a small 

number of individuals and will 

experience little or no annual turnover 


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328A filer survey conducted by a filing agent 

found that at least 64% of its respondents planned 

to have three or fewer account administrators, and 

96% of its respondents planned to have fewer than 

20 users. See Workiva Comment Letter (November 

30, 2021). Moreover, since filers are not required to 

authorize users, technical administrators, or 

delegations, filers who did not choose to authorize 

such individuals or third parties would not have 

any associated burdens. 

329The estimate of 1.3 hours per filer is based on 

the following calculations: For dashboard set up, 1 

hour in the first year ÷ 3 years = 0.3 hours on 

average; for dashboard management, 1 hour per year 

÷ 3 years = 1 hour on average; 0.3 hours for 

dashboard set up + 1 hour for dashboard 

management = 1.3 hours on average for all 

dashboard responsibilities. The estimate of 270,400 

hours is based on the following calculations: 0.3 

hours for dashboard set up × 208,000 filers = 62,400 

hours; 1 hour for dashboard management × 208,000 

filers = 208,000 hours; 62,400 hours + 208,000 

hours = 270,400 hours. 

330 5 U.S.C. 601 et seq. 

331 Id. 

332See Toppan Merrill Comment Letter (regarding 

the individual account credential requirement: 

‘‘Yes, there will be additional costs and confusion 

for individuals and entity filers. It will be beneficial 

for the SEC to provide a well-publicized education 

and an information campaign to help prepare filers 

for the EDGAR Next mandate. We commend the 

SEC for providing the EDGAR Next Beta testing 

environment and hosting introductory webinars. To 

encourage more registrant participation, it would be 

beneficial for the SEC to post step-by-step videos on 

its YouTube channel of each essential part of the 

EDGAR Next process.’’). 

333See Workiva Comment Letter, discussed supra 

note 141 (‘‘All functionality provided by the 

EDGAR Dashboard should be available via APIs 

. . . . The administration burden and ongoing 

maintenance costs [of manually using the 

dashboard] will be significant and could ultimately 

impact the cost burden on the filers’’). 

334See Workiva Comment Letter, discussed supra 

note 302 (asserting regarding the requirement that 

API tokens be manually obtained pursuant to 

multifactor authentication, that ‘‘manual 

intervention result[s] in higher services costs, 

which are hard to accurately estimate at this point 

although we expect it to be far reaching due to the 

percentage of public registrants potentially 

impacted by this.’’). 

with regard to those individuals.328

Consequently, the anticipated aggregate 

average annual burden attributed to the 

dashboard for all filers will be 

approximately 270,400 burden hours, 

based on a three-year average burden of 

1.3 hours per filer.329

VI. Final Regulatory Flexibility 

Analysis 

The Regulatory Flexibility Act 

(‘‘RFA’’) 330 requires an agency, when 

issuing a rulemaking adoption, to 

prepare and make available a Final 

Regulatory Flexibility Analysis 

(‘‘FRFA’’) that describes the impact of 

the final rule on small entities.331 This 

FRFA has been prepared in accordance 

with the RFA and relates to the 

amendments to Rules 10 and 11 of 

Regulation S–T and Form ID described 

in section II.F above. 

A. Need for and Objectives of the Rule 

and Form Amendments 

The purpose of the final amendments 

is to enhance the security of EDGAR 

accounts, improve the ability of filers to 

securely maintain access to their 

EDGAR accounts, facilitate the 

responsible management of EDGAR filer 

credentials, and simplify procedures for 

accessing EDGAR. Among other things, 

the final amendments will require each 

filer to: 

D Authorize individuals to act on its 

behalf on the dashboard only if those 

individuals have obtained individual 

account credentials in the manner 

specified in the EDGAR Filer Manual; 

D Authorize and maintain individuals 

as account administrators to manage 

their EDGAR accounts on the 

dashboard; 

D Confirm annually on EDGAR, 

through their account administrators, 

that all account administrators, users, 

technical administrators and delegated 

entities reflected on the dashboard for 

the filer’s EDGAR account are 

authorized by the filer to act on its 

behalf, and that all information about 

the filer on the dashboard is accurate; 

D Maintain accurate and current 

information on EDGAR concerning the 

filer’s account; and 

D Securely maintain information 

relevant to the ability to access the 

filer’s EDGAR account. 

Filers that choose to connect to the 

optional EDGAR APIs to make 

submissions on EDGAR and take other 

actions, will, among other things, 

generally be required through their 

account administrators to authorize at 

least two technical administrators to 

manage tokens and other technical 

aspects of the EDGAR APIs unless they 

use the API connections and filer API 

tokens of their delegated entities that 

have authorized at least two technical 

administrators, in which case an 

individual at the relevant filer need only 

supply a user API token, if the relevant 

API requires presentation of a user API 

token. 

B. Significant Issues Raised by Public 

Comments 

We received no comments on the 

Initial Regulatory Flexibility Analysis 

contained in the Proposing Release. 

Commenters did state, however, that 

several aspects of the rulemaking would 

have both financial and workload 

impacts on their business and services 

offered, including: the requirement to 

obtain individual account credentials 

resulting in ‘‘additional costs and 

confusion for individuals and small 

entity filers,’’ 332 dashboard 

requirements resulting in 

‘‘administrative burden and ongoing 

maintenance costs,’’ 333 and 

requirements for API tokens resulting in 

‘‘higher service costs.’’ 334

As noted above, to further facilitate 

individuals’ and small entity filers’ 

experience with the EDGAR Next 

transition, Commission staff will begin 

public outreach immediately after the 


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335See section II.H.2. 

336See generally section II.H. 

337See supra text accompanying and following 

note 89. 

338See generally section II.E. 

339See supra text accompanying note 141. 

340See supra text accompanying note 112. 

341 5 U.S.C. 601(6). 

342See 17 CFR 240.0–10(a)). 

343This estimate is based on staff analysis of 

issuers potentially subject to the final amendments, 

excluding co-registrants, with EDGAR filings on 

Form 10–K, or amendments thereto, filed during the 

calendar year of January 1, 2023 to December 31, 

2023. This analysis is based on data from XBRL 

filings, Compustat, Ives Group Audit Analytics, and 

manual review of filings submitted to the 

Commission. 

344See 17 CFR 270.0–10. 

345This estimate is derived from an analysis of 

data obtained from Morningstar Direct as well as 

data filed with the Commission (on Forms N–CSR, 

NPORT–P, 10–Q, and 10–K) for the last quarter of 

2023. 

346 17 CFR 275.0–7. 

347We based this estimate on registered 

investment adviser responses to Item 12 of Form 

ADV. 

348 17 CFR 240.0–10(h). 

issuance of this release.335 Staff will 

publicize the transition to EDGAR Next 

and link to additional information in 

announcements and email distributions, 

SEC social media, and the homepage of 

SEC.gov. Commission staff also will 

provide multiple resources on a 

dedicated EDGAR Next web page to 

assist with the transition, including but 

not limited to, written step-by-step 

guidance for testing a range of 

functionality in the Adopting Beta 

environment and information about staff 

webinars and API technical help 

sessions for the public. On the SEC 

YouTube channel, staff will post videos 

to walk filers through various aspects of 

the EDGAR Next changes. To assist 

filers with any issues that may arise, 

Commission staff will provide dedicated 

telephone support and an email help 

desk—EDGARNextBeta@sec.gov—as 

well as an online form (available in the 

Adopting Beta) to report technical bugs. 

To facilitate the transition to EDGAR 

Next and mitigate the associated costs of 

obtaining individual account credentials 

and setting up and managing the 

dashboard, and obtaining API tokens, 

we are extending the transition period 

for compliance with the final 

amendments from seven months (as 

proposed) to 12 months (as adopted).336

This transition period will provide filers 

six months to prepare during which the 

Adopting Beta will be available, 

followed by six months to enroll in 

EDGAR Next prior to the compliance 

date, followed by an additional three 

months after the compliance date during 

which any remaining filers can enroll. 

The additional three months to enroll in 

EDGAR Next after the compliance date 

should help ease burdens on small 

entities that may need more time to 

transition to EDGAR Next. 

In addition, to minimize 

administrative burden and ongoing 

maintenance costs related to the 

dashboard, we are extending the grace 

period for filers to timely perform 

annual confirmations from two weeks to 

three months.337 Commission staff will 

also offer 12 optional APIs beyond what 

was contemplated in the proposal, as 

well as an API Development Toolkit and 

a sample filing application to assist 

filers in developing their own filing 

software to connect to the APIs.338 As 

discussed above, these new optional 

APIs will replicate much of the account 

management functionality provided on 

the dashboard, which should allow 

filers to reduce burdens and manage 

their EDGAR accounts in a more 

automated manner.339

Furthermore, in a change from the 

proposal, filers with delegated entities 

will be able to use the API connections 

and filer API tokens of their delegated 

entities 340 and will not need to 

authorize technical administrators, so 

long as the delegated entity maintains at 

least two technical administrators. This 

will alleviate the need for filers with 

delegated entities to authorize at least 

two technical administrators, create API 

connections and maintain their own 

filer API tokens in order for their users 

to interact with EDGAR through APIs, 

although individuals at these filers will 

need to generate and present user API 

tokens to interact with the APIs, if those 

APIs require presentation of a user API. 

While filers could rely completely on 

their delegated entities to interact with 

EDGAR on their behalf, certain filers 

may wish to retain the ability to have 

their users interact with EDGAR through 

APIs. This change allows them to do so 

in a cost-effective fashion and, as a 

result, may make APIs more accessible 

for smaller filers that may not have the 

resources to connect to the APIs or 

employ their own technical 

administrators. Individuals at filers 

using their delegated entities’ filer API 

tokens and API connections must 

nevertheless supply their own user API 

tokens to interact with the EDGAR APIs, 

if those APIs require presentation of a 

user API token. 

C. Small Entities Subject to the Rule and 

Form Amendments 

The final amendments will affect 

individuals and entities that have 

EDGAR accounts or that seek to open 

EDGAR accounts. The RFA defines 

‘‘small entity’’ to mean ‘‘small 

business,’’ ‘‘small organization,’’ or 

‘‘small governmental jurisdiction.’’ 341

For purposes of the RFA, under our 

rules, an issuer, other than an 

investment company, is a small entity if 

it had total assets of $5 million or less 

on the last day of its most recent fiscal 

year.342 We estimate there are 800 

issuers that file with the Commission— 

other than investment companies—that 

will be considered small entities for 

purposes of this analysis.343

With respect to investment companies 

and investment advisers, an investment 

company, including a business 

development company, is considered to 

be a small entity if it, together with 

other investment companies in the same 

group of related investment companies, 

has net assets of $50 million or less as 

of the end of its most recent fiscal 

year.344 We estimate that there are 87 

registered investment companies 

(including business development 

companies and unit-investment trusts) 

that will be considered small entities.345

An investment adviser is generally 

considered a small entity if it: (1) has 

assets under management having a total 

value of less than $25 million; (2) did 

not have total assets of $5 million or 

more on the last day of the most recent 

fiscal year; and (3) does not control, is 

not controlled by, and is not under 

common control with another 

investment adviser that has assets under 

management of $25 million or more, or 

any person (other than a natural person) 

that had total assets of $5 million or 

more on the last day of its most recent 

fiscal year.346 We estimate that there are 

471 investment advisers that will be 

considered small entities.347

A transfer agent is considered to be a 

small entity if it: (1) received less than 

500 items for transfer and less than 500 

items for processing during the 

preceding six months (or in the time 

that it has been in business, if shorter); 

(2) transferred items only of issuers that 

would be deemed ‘‘small businesses’’ or 

‘‘small organizations’’ as defined in 17 

CFR 240.0–10; (3) maintained master 

shareholder files that in the aggregate 

contained less than 1,000 shareholder 

accounts or was the named transfer 

agent for less than 1,000 shareholder 

accounts at all times during the 

preceding fiscal year (or in the time that 

it has been in business, if shorter); and 

(4) is not affiliated with any person 

(other than a natural person) that is not 

a small business or small organization 

under 17 CFR 240.0–10.348 We estimate 


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349We based this estimate on transfer agent 

responses to questions 4(a) and 5(a) on their latest 

filing on Form TA–2. 

350 17 CFR 240.0–10(f). 

351This estimate is based on MSRB data filed 

during the calendar year of January 1, 2023 to 

December 31, 2023. 

352 17 CFR 240.0–10(c). 

353This estimate is based on FOCUS Report data 

filed during the calendar year of January 1, 2023 to 

December 31, 2023. 

354 17 CFR 240.0–10(d). 

355 17 CFR 240.0–10(e). 

356 17 CFR 240.0–10(g). 

357See section III.C.2. 

358See the discussion of performance-based 

standards in section IV.D.3. 

359See the discussion of compliance 

requirements in section IV.D.2. 

that there are 131 transfer agents that 

will be considered small entities.349

With respect to municipal securities 

dealers and broker-dealers, a municipal 

securities dealer that is a bank 

(including any separately identifiable 

department or division of a bank) is a 

small entity if it: (1) had, or is a 

department of a bank that had, total 

assets of less than $10 million at all 

times during the preceding fiscal year 

(or in the time that it has been in 

business, if shorter); (2) had an average 

monthly volume of municipal securities 

transactions in the preceding fiscal year 

(or in the time it has been registered, if 

shorter) of less than $100,000; and (3) is 

not affiliated with any person (other 

than a natural person) that is not a small 

business or small organization as 

defined in 17 CFR 240.0–10.350 We 

estimate there are 185 municipal 

securities dealers that will be 

considered small entities.351 A brokerdealer is a small entity if it: (1) had total 

capital (net worth plus subordinated 

liabilities) of less than $500,000 on the 

date in the prior fiscal year as of which 

its audited financial statements were 

prepared pursuant to § 240.17a–5(d) or, 

if not required to file such statements, 

a broker or dealer that had total capital 

(net worth plus subordinated liabilities) 

of less than $500,000 on the last 

business day of the preceding fiscal year 

(or in the time that it has been in 

business, if shorter); and (2) is not 

affiliated with any person (other than a 

natural person) that is not a small 

business or small organization as 

defined in 17 CFR 240.0–10.352 We 

estimate that there are 737 brokerdealers that will be considered small 

entities.353

A clearing agency is a small entity if 

it: (1) compared, cleared and settled less 

than $500 million in securities 

transactions during the preceding fiscal 

year (or in the time that it has been in 

business, if shorter); (2) had less than 

$200 million of funds and securities in 

its custody or control at all times during 

the preceding fiscal year (or in the time 

that it has been in business, if shorter); 

and (3) is not affiliated with any person 

(other than a natural person) that is not 

a small business or small organization 

as defined in 17 CFR 240.0–10.354 We 

estimate there are zero clearing agencies 

that are small entities, as of December 

31, 2023. 

An exchange is a small entity if it: (1) 

has been exempted from the reporting 

requirements of § 242.601 of this 

chapter; and (2) is not affiliated with 

any person (other than a natural person) 

that is not a small business or small 

organization as defined in 17 CFR 

240.0–10.355 We estimate there are zero 

exchanges that are small entities, as of 

December 31, 2023. A securities 

information processor is a small entity 

if it: (1) had gross revenues of less than 

$10 million during the preceding fiscal 

year (or in the time it has been in 

business, if shorter); (2) provided 

service to fewer than 100 interrogation 

devices or moving tickers at all times 

during the preceding fiscal year (or in 

the time that it has been in business, if 

shorter); and (3) is not affiliated with 

any person (other than a natural person) 

that is not a small business or small 

organization under 17 CFR 240.0–10.356

We estimate there are zero securities 

information processors that are small 

entities, as of December 31, 2023. 

Collectively, we estimate that there 

are 2,411 small entities that will be 

potentially subject to the amendments, 

based on our review of data reported as 

of December 31, 2023. 

D. Projected Reporting, Recordkeeping, 

and Other Compliance Requirements 

As noted above, the purpose of the 

amendments will be to update access 

and provide secure management of 

individual and entity filers’ EDGAR 

accounts. The amendments will apply 

to all applicants and current EDGAR 

accounts and will apply to small entities 

to the same extent as other entities, 

irrespective of size. Therefore, we 

generally expect the nature of any 

benefits and cost associated with the 

amendments to be similar for large and 

small entities. As discussed above,357 all 

existing and new EDGAR filers will be 

subject to certain fixed costs to update 

and maintain an EDGAR account under 

the amendments, which may result in a 

proportionally larger burden on small 

filers. 

We expect that the amendments to the 

rules and form to update requirements 

regarding access and management of 

EDGAR accounts will have a small 

incremental effect on existing reporting, 

recordkeeping and other compliance 

burdens for all existing and new EDGAR 

filers, including small entities. At the 

same time, the EDGAR Next changes 

will simplify account management by 

providing an interactive dashboard on 

EDGAR, populated with EDGAR 

account information, as the central 

platform for account administrators and 

other delegated individuals to manage 

access to the account, update account 

information and send communications 

and notifications. Some of the 

amendments, including requirements 

for all filers to confirm the accuracy of 

their account information, including 

authorizations for all account 

administrators, users, technical 

administrators, and/or delegated 

entities, will require the use of 

administrative and technical skills, and 

increase compliance costs for 

registrants, although, as discussed in 

further detail in section IV, we do not 

expect these additional costs will be 

significant. 

E. Agency Action To Minimize Effects 

on Small Entities 

The RFA directs us to consider 

alternatives that will accomplish our 

stated objectives, while minimizing any 

significant adverse impact on small 

entities. In connection with the 

amendments, we considered the 

following alternatives: 

i. Establishing different compliance 

requirements for individual and entity 

EDGAR account managers that take into 

account the resources available to small 

entities; 

ii. Clarifying, consolidating, or 

simplifying compliance and reporting 

requirements under the rules for small 

entities; 

iii. Using performance rather than 

design standards; 358 and 

iv. Exempting small entities from all 

or part of the requirements. 

Regarding the first, third, and fourth 

alternatives,359 we do not believe that 

establishing different compliance 

requirements, using performance rather 

than design standards, or exempting 

small entities from the requirements 

will permit us to obtain our desired 

objectives. We are concerned that each 

of these alternatives would undermine 

our efforts to enhance the security of 

EDGAR, improve the ability of filers to 

securely manage and maintain access to 

their EDGAR accounts, facilitate the 

responsible management of EDGAR filer 

credentials, and simplify procedures for 

accessing EDGAR. The amendments set 

forth uniform requirements for each filer 


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360See Proposing Release, at notes 28–29 

(indicating that 60 to 90% of EDGAR filings may 

be submitted by filing agents). 

361See section III.D.3. 362 Id. 

363 15 U.S.C. 77f, 77g, 77h, 77j, and 77s (a). 364 15 U.S.C. 78c, 78l, 78m, 78n, 78o, 78o–4, 78w, 

and 78ll. 365 15 U.S.C. 77sss. 366 15 U.S.C. 80a–8, 80a–29, 80a–30, and 80a–37. 

to formally authorize individuals to act 

on the filer’s behalf in EDGAR as 

account administrators, users, and 

technical administrators, which will 

allow EDGAR to determine whether 

individuals authorized by the filer were 

accessing and taking actions regarding 

the filer’s EDGAR account. In 

connection with the EDGAR Next 

changes, all individuals accessing 

EDGAR will be required to sign in with 

individual account credentials and 

multifactor authentication, which will 

allow EDGAR to identify the individuals 

accessing EDGAR. As discussed above, 

we believe that by imposing these 

requirements on all existing and 

prospective EDGAR filers, the EDGAR 

Next rulemaking will generally improve 

the security of the EDGAR system by 

establishing a uniform method for 

authorizing, identifying, and tracking all 

individuals authorized to act on each 

filer’s behalf. We anticipate that 

establishing different compliance 

requirements, using performance rather 

than design standards, or exempting 

small entities would result in a 

patchwork compliance regime that 

would frustrate the ability of filing 

agents and other service providers to 

efficiently manage filer credentials and 

manage and maintain access to filers’ 

EDGAR accounts, and would likewise 

frustrate our efforts to simplify 

procedures for accessing EDGAR.360

As noted above,361 the Commission 

considered using a performance-based 

approach rather than the design 

standards used in the EDGAR Next 

changes and the amended rules and 

forms. A more performance-based 

approach would reduce the regulatory 

burden for certain filers by permitting 

them to tailor their EDGAR access 

compliance requirements to fit their 

own particular circumstances. For 

example, small filers could determine 

that they do not need the additional 

security provided by multifactor 

authentication for designated 

individuals to be authorized to act on 

their behalf on the dashboard. 

Furthermore, larger filers might opt to 

authorize and maintain only one 

account administrator rather than 

authorize and maintain two such 

individuals. However, after 

consideration, we believe that 

permitting filers to tailor their EDGAR 

access compliance requirements to fit 

their own particular circumstances 

would diminish the intended benefits of 

the EDGAR Next changes. As discussed 

earlier,362 bypassing the individual 

account credential requirements would 

make it difficult for the Commission to 

match specific filings to the relevant 

individual who made the submissions. 

Likewise, generally allowing filers to 

have only one account administrator 

would increase the likelihood that 

Commission staff could not reach an 

account administrator when it had timesensitive questions about access to or 

activity on the account. Overall, a 

performance-based approach would 

create inconsistencies in improving the 

overall security of EDGAR, facilitating 

the responsible management of EDGAR 

filer credentials, and simplifying 

procedures for accessing EDGAR. In 

addition, any cost savings associated 

with a performance-based approach 

would likely be minimal because filers 

would still incur costs to adjust to new 

EDGAR access requirements. Further, 

this alternative would limit the 

magnitude of the benefits for filers that 

would result from the contemplated 

EDGAR Next changes. 

In addition, establishing different 

compliance requirements, using 

performance rather than design 

standards, or exempting small entities 

could permit individuals to access 

EDGAR accounts for small filers without 

being authorized on the dashboard, 

without multifactor authentication, and 

without their EDGAR permissions being 

individually verified by EDGAR. 

Furthermore, if these exemptions or 

alternatives for small entities were 

implemented so that individuals acting 

on behalf of small entities were not 

required to obtain individual account 

credentials, the Commission would not 

be able to associate individuals with the 

specific filings they submitted on behalf 

of small entities. Collectively, this 

would reduce the security of EDGAR 

accounts for small entities, hinder the 

ability of the Commission and filers to 

prevent and resolve problematic and 

unauthorized filings, and frustrate our 

efforts to require all entities to 

responsibly manage EDGAR filer 

credentials. 

Regarding the second alternative, we 

believe the rulemaking is clear, and that 

clarifying, consolidating, or simplifying 

compliance requirements for EDGAR 

filers, including small entities, is not 

necessary. All EDGAR users currently 

follow the same process and rules to 

access and maintain their EDGAR 

accounts. The changes to EDGAR 

account management will in many ways 

simplify procedures for accessing 

EDGAR and EDGAR account 

management. Among other things, the 

changes will eliminate the need for 

individuals to track and share EDGAR 

passwords, PMACs, and passphrase 

codes for each CIK. Instead, each 

individual will only be responsible for 

tracking a single set of individual 

account credentials, which will be 

issued by Login.gov. Once the 

individual logs into EDGAR using those 

credentials, the dashboard will 

automatically authenticate the 

individual and provide her with the 

appropriate access to each CIK for 

which she had been authorized to take 

action. The dashboard will also display 

any relevant individual codes or tokens 

(such as user API tokens or CCCs), 

instead of requiring the individual to 

personally track or record those codes or 

tokens. This should result in more 

streamlined, modern access processes 

that will benefit all filers, including 

individuals and small entities. 

Statutory Authority 

We are amending Rules 10 and 11 of 

Regulation S–T and Form ID under the 

authority in sections 6, 7, 8, 10, and 

19(a) of the Securities Act,363 sections 3, 

4A, 4B, 12, 13, 14, 15, 15B, 23, and 35A 

of the Exchange Act,364 section 319 of 

the Trust Indenture Act of 1939,365 and 

sections 8, 30, 31, and 38 of the 

Investment Company Act.366

List of Subjects 

17 CFR Part 232 

Administrative practice and 

procedure, Confidential business 

information, Electronic filing, 

Incorporation by reference, Reporting 

and recordkeeping requirements, 

Securities. 

17 CFR Part 239 

Administrative practice and 

procedure, Confidential business 

information, Reporting and 

recordkeeping requirements, Securities. 

17 CFR Part 249 

Administrative practice and 

procedure, Brokers, Fraud, Reporting 

and recordkeeping requirements, 

Securities. 

17 CFR Part 269 

Reporting and recordkeeping 

requirements, Securities, Trusts and 

trustees. 

17 CFR Part 274 

Administrative practice and 

procedure, Electronic funds transfers, 


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Investment companies, Reporting and 

recordkeeping requirements, Securities. 

For the reasons discussed above, we 

are amending title 17, chapter II of the 

Coe of Federal Regulations as follows: 

PART 232—REGULATION S–T— 

GENERAL RULES AND REGULATIONS 

FOR ELECTRONIC FILINGS 

■ 1. The general authority citation for 

part 232 continues to read as follows: 

Authority: 15 U.S.C. 77c, 77f, 77g, 77h, 

77j, 77s(a), 77z–3, 77sss(a), 78c(b), 78l, 78m, 

78n, 78n–1, 78o(d), 78w(a), 78ll, 80a–6(c), 

80a–8, 80a–29, 80a–30, 80a–37, 7201 et seq.; 

and 18 U.S.C. 1350, unless otherwise noted. 

* * * * * 

■ 2. Amend § 232.10 by revising 

paragraph (b), adding paragraph (d), and 

revising the note to § 232.10 to read as 

follows: 

§ 232.10 Application of part 232. 

* * * * * 

(b) Each electronic filer must, before 

filing on EDGAR: 

(1) File electronically the information 

required by Form ID (§§ 239.63, 

249.446, 269.7, and 274.402 of this 

chapter), the application for EDGAR 

access and 

(2) File, by uploading as a Portable 

Document Format (PDF) attachment to 

the Form ID filing, a notarized 

document, signed by the electronic filer 

or its authorized individual, that 

includes the information required to be 

included in the Form ID filing and 

confirms the authenticity of the Form ID 

filing. 

* * * * * 

(d) To file on EDGAR, each electronic 

filer must comply with the EDGAR 

account access and account 

management requirements set forth in 

this section and in the EDGAR Filer 

Manual. 

(1) The electronic filer may only 

authorize individuals to act on its behalf 

on the dashboard if those individuals 

have obtained individual account 

credentials for EDGAR in the manner 

specified in the EDGAR Filer Manual; 

(2) Each electronic filer must 

authorize and maintain at least two 

individuals as account administrators to 

act on the electronic filer’s behalf to 

manage its EDGAR account, except each 

individual or single-member company 

electronic filer must authorize and 

maintain at least one individual as an 

account administrator to manage its 

EDGAR account; 

(3) If the electronic filer chooses to 

connect to an EDGAR Application 

Programming Interface, the electronic 

filer, through its authorized account 

administrator(s), must authorize at least 

two technical administrators to manage 

technical matters related to the 

electronic filer’s connection to any 

EDGAR Application Programming 

Interface, unless the electronic filer 

delegates to a delegated entity that is in 

compliance with the technical 

administrator requirements of this 

paragraph and connects to the EDGAR 

Application Programming Interface 

using its delegated entity’s filer API 

tokens and API connections; 

(4) The electronic filer, through its 

authorized account administrator(s), 

must confirm annually on EDGAR that 

all account administrators, users, 

technical administrators, and/or 

delegated entities reflected on the 

dashboard for its EDGAR account are 

authorized by the electronic filer to act 

on its behalf, and that all information 

about the filer on the dashboard is 

accurate; 

(5) The electronic filer, through its 

authorized account administrator(s), 

must maintain accurate and current 

information on EDGAR concerning the 

electronic filer’s account, including but 

not limited to accurate corporate 

information and contact information; 

and 

(6) The electronic filer, through its 

authorized account administrator(s), 

must securely maintain information 

relevant to the ability to access the 

electronic filer’s EDGAR account, 

including but not limited to access 

through any EDGAR Application 

Programming Interfaces. 

Note 1 to § 232.10: The Commission staff 

carefully review each Form ID, and electronic 

filers should expect that the Commission 

staff will require sufficient time to review the 

Form ID upon its submission. Therefore, any 

applicant seeking EDGAR access is 

encouraged to submit the Form ID for review 

well in advance of the first required filing to 

allow sufficient time for staff to review the 

application. 

■ 3. Amend § 232.11 by: 

■ a. Adding definitions for ‘‘Account 

administrator’’, ‘‘Application 

Programming Interface’’, ‘‘Authorized 

individual’’, ‘‘Dashboard’’, and 

‘‘Delegated entity’’ in alphabetical order; 

■ b. Revising the definitions of ‘‘Direct 

transmission’’ and ‘‘EDGAR Filer 

Manual’’; 

■ c. Removing the note following the 

definition of ‘‘EDGAR Filer Manual’’; 

and 

■ d. Adding definitions for ‘‘Filing 

agent’’, ‘‘Individual account 

credentials’’, Single-member company’’, 

‘‘Technical administrator’’, and ‘‘User’’ 

in alphabetical order. 

The additions and revisions read as 

follows: 

§ 232.11 Definitions of terms used in this 

part. 

* * * * * 

Account administrator. The term 

account administrator means an 

individual that the electronic filer 

authorizes to manage its EDGAR 

account and to make filings on EDGAR 

on the electronic filer’s behalf. 

* * * * * 

Application Programming Interface. 

The term Application Programming 

Interface, or API, means a software 

interface that allows computers or 

applications to communicate with each 

other. 

* * * * * 

Authorized individual. The term 

authorized individual means an 

individual with the authority to legally 

bind an entity or individual for 

purposes of Form ID, or an individual 

with a power of attorney from an 

individual with the authority to legally 

bind an entity or individual for 

purposes of Form ID. The power of 

attorney document must clearly state 

that the individual receiving the power 

of attorney has either general legal 

authority to bind the entity or 

individual or specific legal authority to 

bind the entity or individual for 

purposes of Form ID. 

* * * * * 

Dashboard. The term dashboard 

means an interactive function on 

EDGAR where electronic filers manage 

their EDGAR accounts and individuals 

that electronic filers authorize may take 

relevant actions for electronic filers’ 

accounts. 

Delegated entity. The term delegated 

entity means an electronic filer that 

another electronic filer authorizes, on 

the dashboard, to file on EDGAR on its 

behalf. Delegated entities must 

themselves be electronic filers and must 

follow all rules applicable to electronic 

filers. Delegated entities are not 

permitted to further delegate authority 

to file for a delegating electronic filer, 

nor are they permitted to take action on 

the delegating electronic filer’s 

dashboard. 

Direct transmission. The term direct 

transmission means the transmission to 

EDGAR of one or more electronic 

submissions. 

* * * * * 

EDGAR Filer Manual. The term 

EDGAR Filer Manual means the manual 

that sets forth the requirements for 

access to EDGAR and the procedural 

requirements to make electronic 

submissions on EDGAR. See Rule 301 of 

Regulation S–T (§ 232.301). 

* * * * * 


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Filing agent. The term filing agent 

means any person or entity engaged in 

the business of making submissions on 

EDGAR on behalf of electronic filers. To 

act as a delegated entity for an 

electronic filer, a filing agent must be an 

electronic filer with an EDGAR account. 

* * * * * 

Individual account credentials. The 

term individual account credentials 

means credentials issued to individuals 

for purposes of EDGAR access, as 

specified in the EDGAR Filer Manual, 

and used by those individuals to access 

EDGAR. 

* * * * * 

Single-member company. The term 

single-member company means a 

company that has a single individual 

who acts as the sole equity holder, 

director, and officer (or, in the case of 

an entity without directors and officers, 

holds position(s) performing similar 

activities as a director and officer). 

* * * * * 

Technical administrator. The term 

technical administrator means an 

individual that the electronic filer 

authorizes on the dashboard to manage 

the technical aspects of the electronic 

filer’s connection to EDGAR 

Application Programming Interfaces on 

the electronic filer’s behalf. 

* * * * * 

User. The term user means an 

individual that the electronic filer 

authorizes on the dashboard to make 

submissions on EDGAR on the 

electronic filer’s behalf. 

■ 4. Section 232.301 is revised to read 

as follows: 

§ 232.301 EDGAR Filer Manual. 

Filers must prepare electronic filings 

in the manner prescribed by the EDGAR 

Filer Manual, promulgated by the 

Commission, which sets forth the 

technical formatting requirements for 

electronic submissions. The 

requirements for becoming an EDGAR 

Filer and updating company data are set 

forth in the EDGAR Filer Manual, 

Volume I: ‘‘General Information,’’ 

Version 42 (issued September 27, 2024). 

The requirements for filing on EDGAR 

are set forth in the updated EDGAR Filer 

Manual, Volume II: ‘‘EDGAR Filing,’’ 

Version 71 (September 2024). All of 

these provisions have been incorporated 

by reference into the Code of Federal 

Regulations, which action was approved 

by the Director of the Federal Register 

in accordance with 5 U.S.C. 552(a) and 

1 CFR part 51. You must comply with 

these requirements in order for 

documents to be timely received and 

accepted. The EDGAR Filer Manual is 

available for inspection at the 

Commission and at the National 

Archives and Records Administration 

(NARA). The EDGAR Filer Manual is 

available for website viewing and 

printing in the Commission’s Public 

Reference Room, 100 F Street NE, 

Washington, DC 20549, on official 

business days between the hours of 10 

a.m. and 3 p.m. Operating conditions 

may limit access to the Commission’s 

Public Reference Room. For information 

on the availability of the EDGAR Filer 

Manual at NARA, visit 

www.archives.gov/federal-register/cfr/ 

ibr-locations.html or email 

fr.inspection@nara.gov. The EDGAR 

Filer Manual may also be obtained from 

https://www.sec.gov/edgar/ 

filerinformation/current-edgar-filermanual. 

PART 239—FORMS PRESCRIBED 

UNDER THE SECURITIES ACT OF 1933 

■ 4. The authority citation for part 239 

continues to read, in part, as follows: 

Authority: 15 U.S.C. 77c, 77f, 77g, 77h, 

77j, 77s, 77z–2, 77z–3, 77sss, 78c, 78l, 78m, 

78n, 78o(d), 78o–7 note, 78u–5, 78w(a), 78ll, 

78mm, 80a–2(a), 80a–3, 80a–8, 80a–9, 80a– 

10, 80a–13, 80a–24, 80a–26, 80a–29, 80a–30, 

80a–37, and sec. 71003 and sec. 84001, Pub. 

L. 114–94, 129 Stat. 1321, unless otherwise 

noted. 

* * * * * 

Sections 239.63 and 239.64 are also issued 

under 15 U.S.C. 77f, 77g, 77h, 77j, 77s(a), 

77sss(a), 78c(b), 78l, 78m, 78n, 78o(d), 

78w(a), 80a–8, 80a–24, 80a–29, and 80a–37. 

■ 5. Section 239.63 is revised to read as 

follows: 

§ 239.63 Form ID, application for EDGAR 

access. 

Form ID must be filed by electronic 

filers, or by their account 

administrators, to request EDGAR access 

and to authorize account administrators 

to manage the electronic filer’s EDGAR 

account. 

■ 6. Form ID (referenced in §§ 239.63, 

249.446, 269.7, and 274.402) is revised 

to read as follows: 

Note: Form ID is attached as Appendix A 

at the end of this document. Form ID will not 

appear in the Code of Federal Regulations. 

PART 249—FORMS, SECURITIES 

EXCHANGE ACT OF 1934 

■ 7. The general authority citation for 

part 249 continues to read as follows: 

Authority: 15 U.S.C. 78a et seq. and 7201 

et seq.; 12 U.S.C. 5461 et seq.; 18 U.S.C. 1350; 

Sec. 953(b) Pub. L. 111–203, 124 Stat. 1904; 

Sec. 102(a)(3) Pub. L. 112–106, 126 Stat. 309 

(2012), Sec. 107 Pub. L. 112–106, 126 Stat. 

313 (2012), Sec. 72001 Pub. L. 114–94, 129 

Stat. 1312 (2015), and secs. 2 and 3 Pub. L. 

116–222, 134 Stat. 1063 (2020), unless 

otherwise noted. 

■ 8. Section 249.446 is revised to read 

as follows: 

§ 249.446 Form ID, application for EDGAR 

access. 

Form ID must be filed by electronic 

filers, or by their account 

administrators, to request EDGAR access 

and to authorize account administrators 

to manage the electronic filer’s EDGAR 

account. 

PART 269—FORMS PRESCRIBED 

UNDER THE TRUST INDENTURE ACT 

OF 1939 

■ 9. The authority citation for part 269 

continues to read as follows: 

Authority: 15 U.S.C. 77ddd(c), 77eee, 

77ggg, 77hhh, 77iii, 77jjj, 77sss, and 78ll(d), 

unless otherwise noted. 

■ 10. Section 269.7 is revised to read as 

follows: 

§ 269.7 Form ID, application for EDGAR 

access. 

Form ID must be filed by electronic 

filers, or by their account 

administrators, to request EDGAR access 

and to authorize account administrators 

to manage the electronic filer’s EDGAR 

account. 

PART 274—FORMS PRESCRIBED 

UNDER THE INVESTMENT COMPANY 

ACT OF 1940 

■ 11. The authority citation for part 274 

continues to read as follows: 

Authority: 15 U.S.C. 77f, 77g, 77h, 77j, 

77s, 78c(b), 78l, 78m, 78n, 78n–1, 78o(d), 

80a–8, 80a–24, 80a–26, 80a–29, and sec. 

939A, Pub. L. 111–203, 124 Stat. 1376, unless 

otherwise noted. 

* * * * * 

■ 12. Section 274.402 is revised to read 

as follows: 

§ 274.402 Form ID, application for EDGAR 

access. 

Form ID must be filed by electronic 

filers, or by their account 

administrators, to request EDGAR access 

and to authorize account administrators 

to manage the electronic filer’s EDGAR 

account. 

By the Commission. 

Dated: September 27, 2024 

J. Matthew DeLesDernier, 

Deputy Secretary. 

Note: The following appendix will not 

appear in the Code of Federal Regulations. 


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APPENDIX A—FORM ID 

FORM ID 

APPLICATION FOR EDGAR ACCESS 

Persons who respond to the collection of 

information contained in this form are not 

required to respond unless the form displays 

a current valid OMB control number. 

lllllllllllllllllllll

IMPORTANT INFORMATION 

Complete Form ID by reference to: 

• Rules 10 and 11 of Regulation S–T, 17 

CFR 232.10 and 232.11; 

• The requirements set forth in of Volume 

I of the EDGAR Filer Manual; and 

• The Form ID General Instructions on this 

interface. 

On Form ID, the applicant must authorize 

two (2) individuals as account 

administrators; except an applicant that is an 

individual or single-member company must 

authorize one (1) individual as account 

administrator. 

• The first account administrator listed on 

Form ID will be considered the applicant’s 

EDGAR point of contact (‘‘EDGAR POC’’) 

should the Form ID application be granted. 

• SEC staff will attempt to contact the 

EDGAR POC first but may contact other 

account administrators if the EDGAR POC is 

not available. 

Information submitted on Form ID may 

become public. 

• Do not enter personal contact 

information on Form ID that you do not wish 

to become public. 

• Your Form ID application may be 

rejected if you submit unsolicited sensitive 

personally identifiable information on the 

form or in any attachments. 

lllllllllllllllllllll

Misstatements or omissions of fact in 

connection with an application for EDGAR 

access and/or in a submission on EDGAR 

may constitute a criminal violation under 18 

U.S.C. 1001 and 1030 and/or a violation of 

other criminal and civil laws. If the SEC has 

reason to believe that an application for 

EDGAR access and/or a submission on 

EDGAR is misleading, manipulative, and/or 

unauthorized, the SEC may prevent 

acceptance or dissemination of the 

application/submission and/or prevent future 

submissions or otherwise remove a filer’s 

access to EDGAR pursuant to Rule 15 of 

Regulation S–T, 17 CFR 232.15. 

lllllllllllllllllllll

If your Form ID application is granted, be 

aware that EDGAR filers must comply with 

the rules and regulations governing access to 

the EDGAR system set forth in Regulation S– 

T and the EDGAR Filer Manual, including 

but not limited to the following: 

• Filers must only provide access to 

EDGAR to persons or entities authorized by 

the filer to take action on behalf of the filer. 

• Immediately upon determining that a 

person or entity is no longer authorized to 

take action on the filer’s behalf, filers must 

remove the EDGAR access of that person or 

entity. 

• Filers must inform the SEC immediately 

upon receiving information of any 

unauthorized activity in the filer’s EDGAR 

account. Filers should contact EDGAR Filer 

Support at (202) 551–8900. 

lllllllllllllllllllll

Privacy Act Statement 

AUTHORITIES: The information is sought 

pursuant to 15 U.S.C. 77a et seq., 15 U.S.C. 

77aaa et seq., 78a et seq., 80a–1 et seq., and 

17 CFR 232.10. 

PURPOSE: The information solicited on 

this form will be used to determine whether 

to allow applicants to make filings on 

EDGAR, and, where access is granted, to 

establish and maintain the filer’s EDGAR 

account 

ROUTINE USES: Uses for the information 

collected can be found in the System of 

Records Notice SEC–33: General Information 

Technology Records. See https://

www.sec.gov/about/privacy/sorn/sec-33_sec_

general_information_technology_records.pdf. 

DISCLOSURE: Providing this information 

is voluntary. Failure to provide the 

information requested on this form, however, 

may affect the determination whether to 

allow applicants to make filings on EDGAR. 

lllllllllllllllllllll

PART 1—APPLICATION FOR EDGAR 

ACCESS 

(To be completed by all applicants) 

Is this application for a new EDGAR 

account or for access to an existing EDGAR 

account? 

b New EDGAR account (new EDGAR 

account number, known as a Central Index 

Key (CIK), will be issued) 

b Existing EDGAR account (applicant 

currently has an EDGAR account and Central 

Index Key (CIK)) 

Enter existing CIK account number 

lllllllllllllllllllll

Indicate the reason the applicant is seeking 

access to an existing EDGAR account. 

b Broker-dealer or ‘‘paper filer’’ seeks 

electronic access for the first time in order to 

file electronically on EDGAR 

b Filer lost electronic access to its existing 

CIK account 

b Applicant is the legal successor of the 

filer named on the existing CIK account but 

did not receive access from that filer 

Applicant Information 

Is the applicant a company or an 

individual? 

Only apply as an individual if you seek an 

EDGAR account for yourself as a natural 

person. All others should apply as a 

company. 

b Applicant is a company 

Enter company’s full legal name: 

lllllllllllllllllllll

Conformed name llllllll( (the 

name that will appear on public EDGAR) 

b Applicant is an individual 

Enter individual’s full legal name, including 

middle name: 

First name lllllllllllllll

Middle name llllllllllllll

b No middle name 

Last name llllllllllllllll

Suffix lllllllllllllllll

Conformed name llllllllllll

Applicant Type 

Select one (1) most relevant applicant type. 

Select ‘‘Filer’’ if none of the other applicant 

types listed below apply. 

b Filer 

b Filing Agent 

The ‘‘filing agent’’ applicant type should be 

selected ONLY if the applicant is 

engaged in the business of making 

submissions to EDGAR on behalf of filers 

and does not intend to make live filings 

on its own behalf on EDGAR. A filing 

agent that wishes to make live filings on 

its own behalf should select the ‘‘filer’’ 

applicant type. 

b Funding Portal 

b Institutional Investment Manager (Form 

13F Filer) 

b Investment Company, Business 

Development Company or Insurance 

Company Separate Account 

b Large Trader 

b Municipal Advisor 

b Nationally Recognized Statistical Rating 

Organization 

b Non-Investment Company Applicant 

under the Investment Company Act of 

1940 

b Security-Based Swap Data Repository 

b Security-Based Swap Dealer and Major 

Security-Based Swap Participant 

b Security-Based Swap Execution Facility 

b Transfer Agent 

A ‘‘transfer agent’’ CIK may only be used 

for submitting transfer agent filings on 

EDGAR. 

b Training Agent 

A ‘‘training agent’’ CIK may only be used 

for submitting test filings on EDGAR. 

This applicant type is typically selected 

by a filing agent or third-party EDGAR 

software provider that needs a dedicated 

EDGAR CIK for testing their script or 

software configuration interface with 

EDGAR. 

lllllllllllllllllllll

ONLY FOR NON–PUBLIC DRAFT 

REGISTRATION/OFFERING STATEMENTS 

(DRS/DOS) 

If a company is applying for EDGAR access 

to submit non-public draft registration/ 

offering statements on submission types DRS 

or DOS, select Yes. 

b Yes 

Selecting ‘‘Yes’’ will prevent the new CIK 

number and EDGAR account information 

from being made publicly available on 

SEC.gov until a public filing is made. 

This option is only available for companies 

who plan to submit submission types DRS or 

DOS. 

lllllllllllllllllllll

Applicant’s Mailing Address and Preferred 

Contact Information 

The applicant may list its own information, 

or information for its registered agent, law 

firm, or filing agent (collectively, ‘‘third-party 

service provider’’) in this section. 

b Address is for a non-U.S. location (do not 

select if address is for U.S. territory) 

Street address (line 1) llllllllll

Street address (line 2) (optional) lllll

City llllllllllllllllll

State/U.S. Territory lllllllllll

Zip/Postal code (optional for non-U.S. locations) llllllllllllllllll


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Province/Country llllllllllll

Telephone number (optional) lllllll

Violations of Federal or State Securities 

Laws 

Has the applicant (company or individual) 

been criminally convicted as a result of a 

Federal or state securities law violation, or 

civilly or administratively enjoined, barred, 

suspended, or banned in any capacity (e.g., 

officer or director bar, prohibition from 

associating with brokers, dealers, investment 

advisers, and/or other securities entities, or 

bar from participation in certain industries), 

as a result of a Federal or state securities law 

violation? 

b Yes 

b No 

If you indicate ‘‘Yes,’’ the SEC staff may 

contact you to determine your eligibility for 

EDGAR access. 

lllllllllllllllllllll

PART 2—COMPANY APPLICANT 

INFORMATION 

(To be completed only by applicants who are 

not natural persons) 

Company Business Information 

Company’s Tax or Federal Identification 

Number (do not enter Social Security Number) llllllllllllllllll

llllllllllllllllllll

Legal Entity Identifier (LEI), if any lllll

Legal name lllllllllllllll

Doing business as name, if different from 

legal name lllllllllllllll

U.S. state of incorporation llllllll

If foreign issuer, country of incorporation l

Foreign issuer name, if different than English 

name used in U.S. llll(enter only 

English characters) 

Fiscal year end (mm/dd) lllllllll

Company’s primary website, if any llll

Is the company in good standing in its state 

or country of incorporation? Generally, this 

means a company is legally authorized to do 

business in that state or country and has filed 

all required reports and paid all related fees 

to the relevant jurisdiction. 

b Yes 

b No 

Company’s Primary Business Information 

This must be the applicant company’s 

primary business information, or that of the 

company’s registered agent. Do not enter the 

address of the company’s law firm or filing 

agent. 

You must enter the actual physical 

address; P.O. boxes are not acceptable. 

b Primary business information is the 

same as the mailing address and preferred 

contact information in Part 1. If this box is 

selected, the relevant information will be 

added below. 

b Address is for a non-U.S. location (do 

not select if address is for U.S. territory) 

Street address (line 1) llllllllll

Street address (line 2) (optional) lllll

City llllllllllllllllll

State/U.S. Territory lllllllllll

Zip/Postal code (optional for non-U.S. locations) llllllllllllllllll

Province/Country llllllllllll

Telephone number llllllllllll

Single-Member Company? You should 

select ‘‘Yes’’ if the company only has a single 

individual who acts as the sole equity holder, 

director, and officer (or, in the case of an 

entity without directors and officers, holds 

position(s) performing similar activities as a 

director and officer). 

b Yes 

b No 

lllllllllllllllllllll

PART 3—PROSPECTIVE ACCOUNT 

ADMINISTRATOR INFORMATION 

(To be completed by all applicants) 

Account administrators are individuals 

authorized by the applicant to manage the 

applicant’s EDGAR account on EDGAR 

should the Form ID application be granted. 

Prospective Account Administrator 1 

The first account administrator listed on 

Form ID will be considered the applicant’s 

EDGAR point of contact (‘‘EDGAR POC’’) if 

the Form ID application is granted. 

SEC staff will attempt to contact the 

EDGAR POC first but may contact other 

account administrators if the EDGAR POC is 

not available. 

Enter full legal name, including middle name 

First name lllllllllllllll

Middle name llllllllllllll

b No middle name 

Last name llllllllllllllll

Suffix lllllllllllllllll

Business title/position llllllllll

Is Prospective Account Administrator 1 the 

applicant (for an individual applicant), or an 

employee of the applicant or its affiliate (for 

a company applicant)? 

b Yes 

b No 

Provide the full legal name of the 

prospective account administrator’s 

employer and the employer’s CIK, if any. In 

addition, you must attach to your submission 

a notarized power of attorney authorizing the 

individual as an account administrator to 

manage the applicant’s EDGAR account, as 

set forth more fully in Part 6 of this form. 

Employer (full legal name) llllllll

CIK of employer (if any) lllllllll

Business Address and Contact Information 

b Contact information is the same as the 

mailing address and preferred contact 

information in Part 1. If this option is 

selected, the relevant information will be 

added below. 

b Contact information is the same as the 

primary business information in Part 2. If 

this option is selected, the relevant 

information will be added below. 

b New information added below 

b Address is for a non-U.S. location (do not 

select if address is for U.S. territory) 

Street address (line 1) llllllllll

Street address (line 2) (optional) lllll

City llllllllllllllllll

State/U.S. Territory lllllllllll

Zip/Postal code (optional for non-U.S. locations) llllllllllllllllll

Province/Country llllllllllll

Email llllllllllllllllll

Telephone number llllllllllll

Violations of Federal or State Securities 

Laws 

Has the individual being authorized as 

Prospective Account Administrator 1 been 

criminally convicted as a result of a Federal 

or state securities law violation, or civilly or 

administratively enjoined, barred, 

suspended, or banned in any capacity (e.g., 

officer or director bar, prohibition from 

associating with brokers, dealers, investment 

advisers, and/or other securities entities, or 

bar from participation in certain industries), 

as a result of a Federal or state securities law 

violation? 

b Yes 

b No 

If you indicate ‘‘Yes,’’ the SEC staff may 

contact you to determine your eligibility for 

EDGAR access. 

lllllllllllllllllllll

Prospective Account Administrator 2 

Enter full legal name, including middle name 

First name lllllllllllllll

Middle name llllllllllllll

b No middle name 

Last name llllllllllllllll

Suffix lllllllllllllllll

Business title/position llllllllll

Is Prospective Account Administrator 2 the 

applicant (for an individual applicant), or an 

employee of the applicant or its affiliate (for 

a company applicant)? 

b Yes 

b No 

Provide the full legal name of the 

prospective account administrator’s 

employer and the employer’s CIK, if any. In 

addition, you must attach to your submission 

a notarized power of attorney authorizing the 

individual as an account administrator to 

manage the applicant’s EDGAR account, as 

set forth more fully in Part 6 of this form. 

Employer (full legal name) llllllll

CIK of employer (if any) lllllllll

Business Address and Contact Information 

b Contact information is the same as the 

mailing address and preferred contact 

information in Part 1. If this option is 

selected, the relevant information will be 

added below. 

b Contact information is the same as the 

primary business information in Part 2. If 

this option is selected, the relevant 

information will be added below. 

b New information added below 

b Address is for a non-U.S. location (do not 

select if address is for U.S. territory) 

Street address (line 1) llllllllll

Street address (line 2) (optional) lllll

City llllllllllllllllll

State/U.S. Territory lllllllllll

Zip/Postal code (optional for non-U.S. locations) llllllllllllllllll

Province/Country llllllllllll

Email llllllllllllllllll

Telephone number llllllllllll

Violations of Federal or State Securities 

Laws 

Has the individual being authorized as 

Prospective Account Administrator 2 been 

criminally convicted as a result of a Federal 


khammond on DSK9W7S144PROD with RULES4
106226 Federal Register / Vol. 89, No. 248 / Friday, December 27, 2024 / Rules and Regulations 

or state securities law violation, or civilly or 

administratively enjoined, barred, 

suspended, or banned in any capacity (e.g., 

officer or director bar, prohibition from 

associating with brokers, dealers, investment 

advisers, and/or other securities entities, or 

bar from participation in certain industries), 

as a result of a Federal or state securities law 

violation? 

b Yes 

b No 

If you indicate ‘‘Yes,’’ the SEC staff may 

contact you to determine your eligibility for 

EDGAR access. 

lllllllllllllllllllll

PART 4—BILLING INFORMATION 

(To be completed only by company 

applicants and filing agents) 

Billing Contact for SEC Fee Account and 

Billing 

Enter full legal name, including middle name 

First name lllllllllllllll

Middle name llllllllllllll

b No middle name 

Last name llllllllllllllll

Suffix lllllllllllllllll

Business title/position llllllllll

Employer llllllllllllllll

Billing Business Address and Contact 

Information 

b Contact information is the same as the 

mailing address and preferred contact 

information in Part 1. If this option is 

selected, the relevant information will be 

added below. 

b Contact information is the same as the 

primary business information in Part 2. If 

this option is selected, the relevant 

information will be added below. 

b New information added below 

b Address is for a non-U.S. location (do not 

select if address is for U.S. territory) 

Street address (line 1) llllllllll

Street address (line 2) (optional) lllll

City llllllllllllllllll

State/U.S. Territory lllllllllll

Zip/Postal code (optional for non-U.S. locations) llllllllllllllllll

Province/Country llllllllllll

Email llllllllllllllllll

Telephone number llllllllllll

Violations of Federal or State Securities 

Laws 

Has the billing contact been criminally 

convicted as a result of a Federal or state 

securities law violation, or civilly or 

administratively enjoined, barred, 

suspended, or banned in any capacity (e.g., 

officer or director bar, prohibition from 

associating with brokers, dealers, investment 

advisers, and/or other securities entities, or 

bar from participation in certain industries), 

as a result of a Federal or state securities law 

violation? 

b Yes 

b No 

If you indicate ‘‘Yes,’’ the SEC staff may 

contact you to determine your eligibility for 

EDGAR access. 

lllllllllllllllllllll

PART 5—SIGNATURE 

(To be completed by all applicants) 

An authorized individual of the applicant 

must sign Form ID. 

Refer to the EDGAR Filer Manual, Volume 

I for the definition of authorized individual 

and additional relevant information. 

By signing Form ID, the authorized 

individual authorizes the prospective 

account administrator(s) listed on Form ID to 

manage the filer’s EDGAR account on 

EDGAR on the filer’s behalf. 

Enter full legal name, including middle name 

First name lllllllllllllll

Middle name llllllllllllll

b No middle name 

Last name llllllllllllllll

Suffix lllllllllllllllll

Business title/position llllllllll

Employer llllllllllllllll

Business Address and Contact Information 

b Contact information is the same as the 

mailing address and preferred contact 

information in Part 1. If this option is 

selected, the relevant information will be 

added below. 

b Contact information is the same as the 

primary business information in Part 2. If 

this option is selected, the relevant 

information will be added below. 

b New information added below 

b Address is for a non-U.S. location (do not 

select if address is for U.S. territory) 

Street address (line 1) llllllllll

Street address (line 2) (optional) lllll

City llllllllllllllllll

State/U.S. Territory lllllllllll

Zip/Postal code (optional for non-U.S. locations) llllllllllllllllll

Province/Country llllllllllll

Email llllllllllllllllll

Telephone number llllllllllll

Violations of Federal or State Securities 

Laws 

Has the authorized individual signing this 

application been criminally convicted as a 

result of a Federal or state securities law 

violation, or civilly or administratively 

enjoined, barred, suspended, or banned in 

any capacity (e.g., officer or director bar, 

prohibition from associating with brokers, 

dealers, investment advisers, and/or other 

securities entities, or bar from participation 

in certain industries), as a result of a Federal 

or state securities law violation? 

b Yes 

b No 

If you indicate ‘‘Yes,’’ the SEC staff may 

contact you to determine your eligibility for 

EDGAR access. 

Authorized individual signature lllll

[Notary seal] 

Date llllllllllllllllll

Is Form ID being signed pursuant to a 

Power of Attorney? 

b Yes 

b No 

Person signing Power of Attorney, if 

application is made pursuant to a Power of 

Attorney. Refer to the EDGAR Filer Manual, 

Volume I for more information. 

Enter full legal name, including middle name 

First name lllllllllllllll

Middle name llllllllllllll

b No middle name 

Last name llllllllllllllll

Suffix lllllllllllllllll

Business title/position llllllllll

Employer llllllllllllllll

Person signing Power of Attorney business 

address and contact information. 

b Contact information is the same as the 

mailing address and preferred contact 

information in Part 1. If this option is 

selected, the relevant information will be 

added below. 

b Contact information is the same as the 

primary business information in Part 2. If 

this option is selected, the relevant 

information will be added below. 

b New information added below 

b Address is for a non-U.S. location (do not 

select if address is for U.S. territory) 

Street address (line 1) llllllllll

Street address (line 2) (optional) lllll

City llllllllllllllllll

State/U.S. Territory lllllllllll

Zip/Postal code (optional for non-U.S. locations) llllllllllllllllll

Province/Country llllllllllll

Email llllllllllllllllll

Telephone number llllllllllll

Violations of Federal or State Securities 

Laws 

Has the person who signed the Power of 

Attorney been criminally convicted as a 

result of a Federal or state securities law 

violation, or civilly or administratively 

enjoined, barred, suspended, or banned in 

any capacity (e.g., officer or director bar, 

prohibition from associating with brokers, 

dealers, investment advisers, and/or other 

securities entities, or bar from participation 

in certain industries), as a result of a Federal 

or state securities law violation? 

b Yes 

b No 

If you indicate ‘‘Yes,’’ the SEC staff may 

contact you to determine your eligibility for 

EDGAR access. 

lllllllllllllllllllll

PART 6—DOCUMENTS 

(To be completed by all applicants) 

All filers must upload a notarized Form ID 

authentication document to EDGAR as a PDF 

attachment submitted with your Form ID. 

See the EDGAR Filer Manual, Volume I, for 

more information about the notarized 

authentication document. 

Other documents to be uploaded in certain 

circumstances: 

• Prospective account administrator(s) not 

employed by the applicant, including filing 

agents and other third parties acting on 

behalf of the applicant: 

➢ Must upload to EDGAR a notarized 

Power of Attorney clearly indicating that an 

authorized individual of the applicant, as 

defined in the EDGAR Filer Manual, Volume 

I, gives the individual(s) named as a 

prospective account administrator(s) the 

authority to act as the applicant’s account 

administrator(s) and manage the applicant’s 

EDGAR account. 

• Applicants for access to an existing CIK 

account: 


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Federal Register / Vol. 89, No. 248 / Friday, December 27, 2024 / Rules and Regulations 106227 

➢ Must upload to EDGAR documents that 

clearly establish the applicant’s authority 

over the company or individual whose name 

currently is listed in EDGAR on the existing 

CIK account. 

lllllllllllllllllllll

GENERAL INSTRUCTIONS 

lllllllllllllllllllll

All companies and individuals seeking 

access to file on EDGAR must refer to Rules 

10 and 11 of Regulation S–T, Volume I of the 

EDGAR Filer Manual, and these instructions. 

All applicants must: 

(1) Complete and submit Form ID in 

electronic format on the EDGAR Filer 

Management website; and 

(2) Create a copy of the completed, 

electronically submitted Form ID; have an 

authorized individual of the filer sign it in 

the ‘‘Form ID: Notarized Authentication’’ part 

in the presence of an official notary public; 

and upload that authenticating document to 

the EDGAR Filer Management website. 

Before beginning: Form ID must be 

completed and submitted by an individual 

authorized by the applicant to do so. 

• An account administrator is a person 

authorized by the filer to manage the filer’s 

EDGAR account on EDGAR on behalf of the 

filer. 

• Each applicant must identify one or 

more prospective account administrator(s) 

that the applicant authorizes on Form ID. If 

the Form ID application is granted, the 

prospective account administrator(s) listed 

on Form ID will become the initial account 

administrators of the applicant. 

• Account administrators must create 

individual account credentials in the manner 

specified in the EDGAR Filer Manual. When 

entering email addresses for individuals on 

Form ID, note that email addresses may be 

visible to other persons with access to the 

EDGAR Filer Management dashboard. 

Accordingly, individuals should enter email 

addresses that they intend to use for EDGAR 

and other business purposes, which may be 

different from the email address that they use 

for personal purposes. Email addresses that 

individuals provide to Login.gov for 

individual account credentials should match 

the email addresses they provide on Form ID. 

The ‘‘EDGAR Filer Manual Volume I: 

General Information’’ contains additional 

requirements regarding how to file 

electronically, including how to obtain 

individual account credentials, authorize 

account administrators, and use the CIK and 

CCC. 

Note that information submitted on Form 

ID may become public. Do not include 

personally identifiable information, such as 

personal addresses and contact information 

that the applicant does not wish to become 

public. 

Misstatements or omissions of fact in 

connection with an application for EDGAR 

access and/or in a submission on EDGAR 

may constitute a criminal violation under 18 

U.S.C. 1001 and 1030 and/or a violation of 

other criminal and civil laws. If the SEC has 

reason to believe that an application for 

EDGAR access and/or a submission on 

EDGAR is misleading, manipulative, and/or 

unauthorized, the SEC may prevent 

acceptance or dissemination of the 

application/submission and/or prevent 

future submissions or otherwise remove a 

filer’s access to EDGAR pursuant to Rule 15 

of Regulation S–T, 17 CFR 232.15. 

Complete all items that are relevant to the 

application. If an item does not apply to the 

application, leave that item blank. 

For assistance with procedural and 

technical questions about electronic filing or 

substantive questions, see the ‘‘EDGAR Filer 

Manual Volume II: Section 2.3.4 (Getting 

Help with EDGAR). 

lllllllllllllllllllll

PART 1—APPLICATION FOR EDGAR 

ACCESS 

(To be completed by all applicants) 

Indicate whether EDGAR access is being 

requested for a new CIK account or an 

existing CIK account. If access is being 

requested for an existing CIK account, 

indicate the basis for the request—whether 

the applicant is a broker-dealer or ‘‘paper 

filer’’ who wants to start filing electronically 

on EDGAR, lost electronic access to their CIK 

account, or is the legal successor of the filer 

named on the existing CIK account but did 

not receive access from that filer. A filer that 

has lost electronic access because it failed to 

satisfy annual confirmation requirements or 

because its account administrators are no 

longer available should select the ‘‘lost 

electronic access’’ option. 

If the applicant is applying for access to an 

existing CIK account, some of the filer’s 

currently publicly available corporate and 

contact information will be prepopulated 

into Form ID. That information can be 

updated on Form ID, but doing so will not 

update the filer’s information in EDGAR 

(other than the filer’s account administrator 

information). Changes to the filer’s corporate 

and contact information must be made in 

EDGAR after the applicant’s Form ID 

application is granted. However, filers who 

are broker-dealers that obtained an EDGAR 

account by submitting a Form BD to FINRA 

would need to update their information with 

FINRA directly. Broker-dealers that have 

made a full withdrawal of their registration, 

by submitting a Form BDW that has been 

accepted, should apply for a new EDGAR 

account instead of applying for access to the 

existing EDGAR account associated with the 

withdrawn registration. 

Applicants should identify themselves as 

individuals or companies. 

Provide the applicant’s full legal name in 

English. Note that the applicant’s name will 

be automatically conformed following 

submission to meet EDGAR standards. 

Specifically: 

1. Leading and trailing blank spaces will be 

removed. Any embedded sequences of two or 

more spaces will be replaced with a single 

space. 

2. For companies, the following words will 

be removed if they are the first word of the 

name: 

A 

An 

The 

3. For companies, the following text 

substitutions will be applied to all words 

except the first: 

Original text Conformed text 

Company ........................... Co. 

Corporation ........................ Corp. 

Incorporated ....................... Inc. 

Incorporation ...................... Inc. 

And .................................... & 

4. For companies, the following 

substitution will be applied if the word is 

neither the first in the name, nor is 

immediately followed by the word 

‘‘Partnership’’: 

Original text Conformed text 

Limited ............................... Ltd. 

5. For individuals, the name components 

(‘‘Last,’’ ‘‘First,’’ ‘‘Middle,’’ and ‘‘Suffix’’) will 

be combined left-to-right (separated by 

spaces) into a single field and truncated at 

150 characters. 

6. For individuals with a suffix, the 

following text substitutions will be applied: 

Original text Conformed text 

Junior ................................. JR. 

Senior ................................ SR. 

Select one (1) applicant type to indicate 

whether the applicant will send electronic 

submissions as one of the listed filer types. 

Indicate whether the filer is applying for 

EDGAR access to submit non-public draft 

registration or offering statements on 

submission type DRS or DOS. If so, the 

applicant’s new CIK number and EDGAR 

contact information will not be listed on the 

public EDGAR company database until the 

applicant makes a public filing. 

Provide the preferred mailing address and 

contact information for the applicant. A 

company applicant should provide 

information for the department, unit, or 

group most directly responsible for the filer’s 

EDGAR submissions. This may be the 

applicant’s registered agent, law firm, or 

filing agent. In that case, identify them in the 

mailing address and contact information, but 

do not include any specific individuals by 

name or any personally identifiable 

information that you do not want to make 

publicly available because the mailing 

address and contact information will 

generally be publicly available. 

Indicate whether the applicant has been 

criminally convicted as a result of a Federal 

or state securities law violation, or civilly or 

administratively enjoined, barred, 

suspended, or banned in any capacity (e.g., 

officer or director bar, prohibition from 

associating with brokers, dealers, investment 

advisers, and/or other securities entities, or 

bar from participation in certain industries), 

as a result of a Federal or state securities law 

violation. 

lllllllllllllllllllll

PART 2—COMPANY INFORMATION 

(To be completed only by applicants who are 

not natural persons) 

Provide the applicant’s tax or Federal 

identification number, the number issued by 

the Internal Revenue Service. (This does not 


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106228 Federal Register / Vol. 89, No. 248 / Friday, December 27, 2024 / Rules and Regulations 

apply to individuals. Accordingly, do not 

enter a Social Security number.) If an 

investment company applicant is organized 

as a series company, the investment company 

may use the tax or Federal identification 

number of any one of its constituent series. 

Applicants that have applied for but not yet 

received their tax or Federal identification 

number and foreign applicants that do not 

have a tax or Federal identification number 

must include all zeroes. 

Provide the applicant’s legal entity 

identifier (LEI), if any. 

Indicate whether applicant is in good 

standing in its state or country of 

incorporation. Generally, this means a 

company is legally authorized to do business 

in that state or country and has filed all 

required reports and paid all related fees to 

the relevant jurisdiction. 

Provide the filer’s state of incorporation 

and fiscal year end. Select ‘‘none’’ for state 

of incorporation and ‘‘N/A’’ for fiscal year 

end if the filer has not incorporated. Foreign 

filers should also include their country of 

organization. If the filer’s fiscal year does not 

end on the same date each year (e.g., falls on 

last Saturday in December), the filer must 

enter the date the current fiscal year will end. 

Provide the company’s primary website, if 

any. 

Provide the applicant company’s primary 

business information or that of the 

company’s registered agent. Do not enter the 

address of the company’s law firm or filing 

agent. 

Indicate whether the filer is a singlemember company. This refers to a company 

that only has a single individual who acts as 

the sole equity holder, director, and officer 

(or, in the case of an entity without directors 

and officers, holds position(s) performing 

similar activities as a director and officer). 

lllllllllllllllllllll

PART 3—PROSPECTIVE ACCOUNT 

ADMINISTRATOR INFORMATION 

(To be completed by all applicants) 

Identify the individuals being authorized 

as prospective account administrator(s) who 

will manage the filer’s EDGAR account on 

the filer’s behalf, should the Form ID 

application be granted, including the account 

administrator(s) business title(s)/position(s), 

address(es), and contact information. 

Individual filers and single-member 

companies must authorize at least one 

prospective account administrator. All other 

filers must authorize two prospective account 

administrators on Form ID. Additional 

account administrators may be added 

through the Filer Management dashboard, 

should the Form ID application be granted. 

For each individual being authorized as a 

prospective account administrator, indicate 

whether the individual has been criminally 

convicted as a result of a Federal or state 

securities law violation, or civilly or 

administratively enjoined, barred, 

suspended, or banned in any capacity (e.g., 

officer or director bar, prohibition from 

associating with brokers, dealers, investment 

advisers, and/or other securities entities, or 

bar from participation in certain industries), 

as a result of a Federal or state securities law 

violation. 

If an individual being authorized as a 

prospective account administrator is not the 

applicant (in the case of an individual 

applicant), or an employee of the applicant 

or its affiliate (in the case of a company 

applicant), disclose that fact and provide the 

name and CIK (if any) of the prospective 

account administrator’s employer. In 

addition, a notarized power of attorney 

authorizing the prospective account 

administrator must be attached in Part 6. 

For more information on account 

administrators, see Rules 10 and 11 of 

Regulation S–T and Volume I of the EDGAR 

Filer Manual. 

lllllllllllllllllllll

PART 4—BILLING INFORMATION 

(To be completed only by company 

applicants and filing agents) 

Billing information is used if questions 

arise related to account and billing matters, 

such as: 

1. Accounts activity statements 

2. Account receivable letters 

3. Refund questions 

Identify the individual who should receive 

account information and/or billing invoices 

from the SEC and include their email 

address. Ensure the accuracy of the email 

address and maintain an accurate, active 

email address in the EDGAR Filing website. 

EDGAR will send communications to the 

email address if there are questions 

pertaining to the account and billing 

information, and failure to maintain an 

accurate, active email address could result in 

failure to receive EDGAR account statements. 

Indicate whether the billing contact has 

been criminally convicted as a result of a 

Federal or state securities law violation, or 

civilly or administratively enjoined, barred, 

suspended, or banned in any capacity (e.g., 

officer or director bar, prohibition from 

associating with brokers, dealers, investment 

advisers, and/or other securities entities, or 

bar from participation in certain industries), 

as a result of a Federal or state securities law 

violation. 

lllllllllllllllllllll

PART 5—SIGNATURE 

(To be completed by all applicants) 

If the applicant is not a natural person, 

indicate the capacity in which the authorized 

individual signs the Form ID on behalf of the 

applicant (business title/position). The 

authorized individual must be an individual 

with the authority to legally bind the 

applicant, or an individual with a power of 

attorney from an individual with the 

authority to legally bind the applicant for 

purposes of Form ID. 

If the applicant is an individual, the 

applicant must sign the Form ID and should 

list their business title/position as 

‘‘applicant,’’ unless the applicant executes a 

notarized power of attorney authorizing a 

third-party individual to sign the Form ID on 

the applicant’s behalf. 

Indicate whether the authorized individual 

signing the Form ID has been criminally 

convicted as a result of a Federal or state 

securities law violation, or civilly or 

administratively enjoined, barred, 

suspended, or banned in any capacity (e.g., 

officer or director bar, prohibition from 

associating with brokers, dealers, investment 

advisers, and/or other securities entities, or 

bar from participation in certain industries), 

as a result of a Federal or state securities law 

violation. 

Indicate whether Form ID is being signed 

pursuant to a power of attorney. 

If another person signs on behalf of the 

applicant, confirm in writing the authority of 

that person to sign by attaching a notarized 

power of attorney to the Form ID. For more 

information on the documentation needed to 

confirm the authority of a person signing the 

Form ID on behalf of the applicant, see 

Volume I of the EDGAR Filer Manual. 

• If relevant, provide the name, address, 

and contact information for the person 

signing the power of attorney. Indicate 

whether the person signing the power of 

attorney has been criminally convicted as a 

result of a Federal or state securities law 

violation, or civilly or administratively 

enjoined, barred, suspended, or banned in 

any capacity (e.g., officer or director bar, 

prohibition from associating with brokers, 

dealers, investment advisers, and/or other 

securities entities, or bar from participation 

in certain industries), as a result of a Federal 

or state securities law violation. 

• For Form IDs signed in connection with 

a power of attorney document, the person 

signing the power of attorney should indicate 

in the business title/position field: ‘‘By POA 

from [(a) name of the authorized individual 

signing the power of attorney (if opening an 

account for a natural person); or (b) name and 

business title/position of the authorized 

individual signing the power of attorney (if 

opening an account for a company)].’’ For 

example, a filing agent signing Form ID 

pursuant to a power of attorney from Roger 

Smith, the Chief Executive Officer of the 

applicant, could provide in the business title/ 

position field: ‘‘By POA from Roger Smith, 

CEO.’’ 

The applicant must upload a notarized 

copy of Form ID and any other required 

attachments to the electronic Form ID filing. 

The Form ID authenticating document must 

be attached to the electronic Form ID filing 

in PDF format. PDF attachments cannot: (i) 

be blank; (ii) be image-only; or (iii) contain 

active contents (Actions, embedded 

JavaScript, etc.), external references 

(Destinations, Hyperlinks, etc.), passwords, 

or document security controls. 

lllllllllllllllllllll

PART 6—DOCUMENTS 

(To be completed by all applicants) 

Attach the mandatory notarized 

authenticating document in PDF format 

(Form ID authenticating document). The 

mandatory Form ID authenticating document 

must include the following information: 

• Signature of Authorized Individual 

• Printed Name of Signature 

• Title of Person Signing 

• Notary Signature and Seal 

Other documents to be provided with the 

Form ID must be attached in this part as well, 

including power of attorney documents. If an 

account administrator is not an employee of 


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Federal Register / Vol. 89, No. 248 / Friday, December 27, 2024 / Rules and Regulations 106229 

the applicant or its affiliates, or if the 

individual signing Form ID is doing so 

pursuant to a power of attorney, a notarized 

power of attorney must be attached. Do not 

upload documents containing potentially 

sensitive personally identifiable information, 

such as birth certificates, driver’s licenses, or 

passports. Applicants seeking access to an 

existing CIK must upload documents that 

clearly establish their authority over the 

company or individual whose name is 

currently listed in EDGAR on the existing 

CIK account. For more information on 

documents that may need to be submitted 

with the Form ID application, see Volume I, 

section 3, of the EDGAR Filer Manual. 

[FR Doc. 2024–30494 Filed 12–19–24; 4:15 pm] 

BILLING CODE 8011–01–P 


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